Toledo v. State

2022 Ohio 1192
CourtOhio Court of Appeals
DecidedApril 8, 2022
DocketL-21-1031 & L-21-1032
StatusPublished
Cited by1 cases

This text of 2022 Ohio 1192 (Toledo v. State) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Toledo v. State, 2022 Ohio 1192 (Ohio Ct. App. 2022).

Opinion

[Cite as Toledo v. State, 2022-Ohio-1192.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

City of Toledo Court of Appeals No. L-21-1031 L-21-1032 Appellant/Cross-appellee Trial Court No. CI0201802922 v.

State of Ohio DECISION AND JUDGMENT

Appellee/Cross-appellant Decided: April 8, 2022

*****

Dale R. Emch, Law Director, John T. Madigan, Senior Attorney, and Jeffrey B. Charles, Chief of Litigation, for appellant/cross/appellee.

Dave Yost, Ohio Attorney General, Caitlyn Nestleroth Johnson, Iris Jin, and Garrett M. Anderson, Assistant Attorneys General, for appellee/cross- appellant.

ZMUDA, J.

I. Introduction

{¶ 1} Appellant/cross-appellee, the city of Toledo, appeals the judgment of the

Lucas County Court of Common Pleas, finding a motion for summary judgment filed by

appellee/cross-appellant, the state of Ohio, well-taken, in part. Because we find that the

trial court erred by failing to address certain arguments raised by the parties below on mootness grounds, we reverse and remand this matter to the trial court with instructions

to consider those arguments.

A. Facts and Procedural Background

{¶ 2} This is the latest in a line of appeals arising out of the state’s attempt to

regulate municipalities’ use of automated traffic law photo-monitoring devices to come

before this court.1 On June 28, 2018, the city filed its complaint in the present action,

seeking a declaratory judgment that Am.Sub.H.B. No. 64, the state’s biennial budget bill

(“H.B. 64”), violates Article XVIII, Section 3, of the Ohio Constitution (the “home rule

provision”), and requesting injunctive relief preventing the enforcement of the same.

{¶ 3} While the matter was pending before the trial court, the General Assembly

passed the state’s two-year transportation budget bill, 2019 Am.Sub.H.B. No. 62 (“H.B.

62”). Among other things, H.B. 62 requires a law enforcement officer to be present at

every photo enforcement device location at all times during operation, reduces or

eliminates the state’s funding to local authorities that utilize photo enforcement programs,

confers “exclusive jurisdiction” over actions involving challenges to citations issued

pursuant to a photo enforcement program to municipal and county courts, and requires

local authorities to provide advance and non-recoverable court deposits to cover “all

applicable court costs and fees” for civil actions related to the photo enforcement

programs.

1 For a summary of the underlying facts, see our decision in City of Toledo v. State, 72 N.E.3d 692, 2017-Ohio-215 (6th Dist.).

2. {¶ 4} In response to the enactment of H.B. 62, the city amended its complaint on

May 24, 2019. In its amended complaint, the city alleged that H.B. 62 was

unconstitutional under the home rule provision of the Ohio Constitution, and sought the

same declaratory and injunctive relief concerning H.B. 62 as it requested in its original

complaint concerning H.B. 64.

{¶ 5} Two weeks after the city filed its amended complaint, the state filed a

motion to dismiss, in which it argued that the city’s claims challenging the

constitutionality of H.B. 62 were without merit because “[t]he Ohio Constitution vests the

General Assembly with the authority to pass legislation specifying how state money is

spent and to regulate lower courts. The Home Rule Amendment does not vest cities with

the ability to veto duly enacted state laws because of how they may impact cities.”

{¶ 6} Before the trial court ruled on its motion to dismiss, the state filed an answer

to the city’s amended complaint on December 11, 2019, and then filed a motion for

summary judgment on January 31, 2020. In its motion for summary judgment, the state

argued that the city’s constitutional challenge to the contested provisions of H.B. 64

(referred to by the state as the “2015 Set-Off Law”) was moot because those provisions

were repealed and replaced by the enactment of H.B. 62.

{¶ 7} Moreover, the state argued that the contested provisions in H.B. 62 (referred

to by the state as the “Reporting and Jurisdiction Law”) were constitutional based upon

the General Assembly’s constitutional “power to regulate lower courts and to decide how

state money is spent.” The state recognized the power conferred upon cities by the home

3. rule provision of the Ohio Constitution, but insisted that such power was limited and

must yield to state exercise of legislative authority granted to the General Assembly by

the Ohio Constitution, including the General Assembly’s express authority to regulate

lower courts and spend state money. Finally, the state contended that, to the extent the

home rule provision is implicated in this case, the statutes enacted pursuant to H.B. 62 do

not contravene the home rule provision.

{¶ 8} On February 13, 2020, the city filed its memorandum in opposition to the

state’s motion for summary judgment. The city advanced several arguments as to why

the contested provisions in H.B. 62 violate the Ohio Constitution. The city argued that

the provisions violate the home rule provision for the same reasons that substantively

similar portions of S.B. 342 were deemed unconstitutional by the Ohio Supreme Court in

Dayton v. State, 151 Ohio St.3d 168, 2017-Ohio-6909, 87 N.E.3d 176. The city

additionally argued that the contested provisions of H.B. 62 were unconstitutional

because they (1) impose unconstitutional conditions that seek to accomplish what the

state has previously been enjoined from doing by several courts, (2) violate the separation

of powers doctrine, (3) violate the one-subject rule, (4) violate Section 26, Article II of

the Ohio Constitution (the uniformity clause), (5) run afoul of the retroactivity clause of

the Ohio Constitution, (6) are void for vagueness, (7) violate the Modern Courts

Amendment to the Ohio Constitution by prescribing procedural rules to be followed by

Ohio’s municipal courts, and (8) violate the Equal Protection Clause of the Ohio

Constitution.

4. {¶ 9} The state filed its reply to the city’s memorandum on February 19, 2020. In

its reply, the state insisted that the contested provisions of H.B. 62 were distinguishable

from the statutes promulgated under S.B. 342 and H.B. 64 that were previously struck

down. The state argued that the city’s arguments based upon the home rule provision fail

because the city relied upon cases “resolving the constitutionality of other dissimilar

traffic-camera laws.”

{¶ 10} Additionally, the state urged that the city’s unconstitutional conditions

argument failed because “there is no such thing as an unconstitutional conditions doctrine

claim in Ohio law.” Pointing to the Ohio Supreme Court’s decision in City of Toledo,

supra, 154 Ohio St.3d 41, 2018-Ohio-2358, 110 N.E.3d 1257, the state argued that the

city’s separation of powers argument must fail. The state further insisted that the

contested provisions of H.B. 62 did not violate the one-subject rule and applied uniformly

throughout the state. Moreover, the state argued that the city’s retroactivity claim must

be dismissed under the Ohio Supreme Court’s decision in Toledo Cty. Sch. Dist. Bd. of

Edn. v. State Bd. of Edn., 146 Ohio St.3d 356, 2016-Ohio-2806, 56 N.E.3d 950, holding

that the Retroactivity Clause of the Ohio Constitution does not protect political

subdivisions.

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2022 Ohio 1192, Counsel Stack Legal Research, https://law.counselstack.com/opinion/toledo-v-state-ohioctapp-2022.