Toledo v. State

CourtOhio Court of Appeals
DecidedMay 5, 2026
Docket25AP-872
StatusPublished

This text of Toledo v. State (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, (Ohio Ct. App. 2026).

Opinion

[Cite as Toledo v. State, 2026-Ohio-1625.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

City of Toledo, :

Plaintiff-Appellant, : No. 25AP-872 (C.P.C. No. 24CV-8714) v. : (REGULAR CALENDAR) State of Ohio, :

Defendant-Appellee. :

D E C I S I O N

Rendered on May 5, 2026

On brief: John T. Madigan and Jeffrey B. Charles, for appellant. Argued: John T. Madigan.

On brief: Dave Yost, Attorney General, Stephen P. Tabatowski, and Gregory A. Rustico, for appellee. Argued: Stephen P. Tabatowski.

APPEAL from the Franklin County Court of Common Pleas

EDELSTEIN, J.

{¶ 1} Plaintiff-appellant, City of Toledo, appeals from a decision and judgment entry of the Franklin County Court of Common Pleas granting the motion for summary judgment of defendant-appellee, the State of Ohio. For the following reasons, we affirm with modifications. I. Facts and Procedural History

{¶ 2} Under former Toledo Municipal Code 313.12, Toledo operated a municipal camera-enforced traffic program to issue fines to drivers for both speeding and traffic light No. 25AP-872 2

violations within the city. (Compl. at ¶ 1.) When the cameras detected a traffic law violation, Toledo sent a traffic ticket to the registered owner of the vehicle that committed the violation. (Compl. at ¶ 2.) The registered owner could avoid responsibility by providing an affidavit stating the name and address of the person operating the vehicle at the time of the violation or by providing a law enforcement report indicating the vehicle had been reported stolen prior to the time of the violation. (Compl. at ¶ 2.) {¶ 3} In 2019, as part of H.B. 62, the General Assembly enacted R.C. 5747.502 (“the spending setoff”) to offset the amount of local government funding the state distributes to a municipality that chooses to operate a camera-enforced traffic program based on the amount of money the municipality collected from the program. (Compl. at ¶ 4.) R.C. 5747.502 requires the municipality to file with the tax commissioner a report of the gross traffic camera fines collected during the preceding fiscal year, and the tax commissioner then computes a local government fund adjustment or a residual adjustment for the municipality. The statute specifically directs the commissioner to reduce local government fund payments to a municipality based on the local government fund adjustment. R.C. 5747.502(C)(1). {¶ 4} In May 2019, Toledo filed a complaint in the Lucas County Court of Common Pleas challenging the constitutionality of certain provisions of H.B. 62, including the spending setoff in R.C. 5747.502 (“the Lucas County case”). Toledo sought a declaratory judgment, a preliminary injunction, and a permanent injunction. (Compl. at ¶ 5.) On July 1, 2019, Toledo obtained a preliminary injunction in the Lucas County case enjoining the state from enforcing the contested provisions and from reducing Toledo’s local government funds for noncompliance with R.C. 5747.502. (Compl. at ¶ 7; Ex. 1.) Toledo continued to operate its camera-enforced traffic program until June 24, 2020, when the Supreme Court of Ohio issued its decision in State ex rel. Magsig v. Toledo, 2020-Ohio- 3416, holding municipal courts have exclusive jurisdiction over civil traffic enforcement violations. (Compl. at ¶ 7.) Following the Supreme Court’s decision in Magsig, on August 18, 2020, the Lucas County Court of Common Pleas partially vacated the portion of the preliminary injunction in the Lucas County case enjoining the state from enforcing R.C. 1901.20(A)(1) and 1907.02(C). (Compl. at ¶ 7.) No. 25AP-872 3

{¶ 5} The state then moved for summary judgment in the Lucas County case. (Compl. at ¶ 8.) The trial court determined several of Toledo’s claims were moot based on Toledo’s suspension of its camera-enforced traffic program. (Compl. at ¶ 8; Ex. 2.) Additionally, the trial court found the spending setoff provision in R.C. 5747.502 was unconstitutional and issued a permanent injunction enjoining the enforcement of R.C. 5747.502. (Compl. at ¶ 8; Ex. 2.) Both parties appealed, and the Sixth District Court of Appeals reversed the trial court’s ruling that Toledo’s claims were moot, remanding the case to the trial court for consideration of those claims. Toledo v. State, 2022-Ohio-1192 (6th Dist.). The Sixth District Court of Appeals did not reach the question of the constitutionality of R.C. 5747.502. Id. at ¶ 20. {¶ 6} While the Lucas County case was still pending on remand, the Supreme Court issued a decision in Newburgh Heights v. State, 2022-Ohio-1642. The court ruled the spending setoff provisions of R.C. 5747.502 were constitutional and did not violate the Home Rule Amendment in Article XVIII of the Ohio Constitution, holding “[t]he General Assembly therefore has exclusive discretion to reduce the appropriation of local- government funds to a municipality in the amount that the municipality has collected in fines from citations issued based on the operation of traffic cameras.” Newburgh Hts. at ¶ 5. Based on Newburgh Heights, the trial court in the Lucas County case vacated its prior injunction and, in an August 29, 2022 order and judgment, granted the state’s motion for summary judgment. Toledo v. State, Lucas C.P. No. CI-201802922. {¶ 7} After the Supreme Court’s decision in Newburgh Heights, the Department of Taxation notified Toledo it would enforce R.C. 5747.502 and reduce Toledo’s share of local government fund distribution by the amount of money Toledo received during the operation of its camera-enforced traffic system from July 1, 2019 through August 29, 2022, the duration of the injunction in the Lucas County case. (Compl. at ¶ 22-23.) Toledo collected $6,856,864 from its camera-enforced traffic system during this timeframe. (Compl. at ¶ 24.) {¶ 8} On June 12, 2024, Toledo filed the instant complaint in the Lucas County Court of Common Pleas seeking (1) preliminary and permanent injunctions prohibiting the state from enforcing R.C. 5747.502 or reducing Toledo’s local government funds; (2) an order requiring the state to restore all local government fund distributions to Toledo that No. 25AP-872 4

were withheld related to the effective dates of the injunction from the Lucas County case; and (3) a declaratory judgment declaring the enforcement of R.C. 5747.502 and reduction of local government fund distributions to Toledo related to the effective dates of the injunction is unconstitutional or otherwise invalid. Toledo generally argued the state cannot enforce R.C. 5747.502 for the period the Lucas County case injunction was in effect, from July 1, 2019 to August 29, 2022. (Compl. at ¶ 25.) On the state’s motion, the Lucas County Court of Common Pleas transferred venue to Franklin County. {¶ 9} Once venue was transferred to Franklin County, the state moved to dismiss Toledo’s complaint, arguing it was not violating the injunction, R.C. 5747.502 is and always has been constitutional, and R.C. 5703.38 deprived the trial court of subject-matter jurisdiction to enjoin orders, determinations, or directions of the Department of Taxation. In a March 28, 2025 entry, the trial court denied the state’s motion to dismiss, determining it would not engage in statutory interpretation at the pleading stage, and finding Toledo sufficiently pled the elements of declaratory judgment to survive a motion to dismiss. {¶ 10} Thereafter, in July 2025, the parties filed cross-motions for summary judgment. The state argued R.C. 5703.38 precludes courts from issuing injunctive relief suspending or staying any order of the Department of Taxation. Additionally, the state argued R.C. 5747.502 plainly directs the tax commissioner to compute local government funds on a rolling basis, and the Supreme Court’s decision in Newburgh Heights expressly found the spending setoff provisions of R.C. 5747.502 to be constitutional.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Sears v. Weimer
55 N.E.2d 413 (Ohio Supreme Court, 1944)
State Ex Rel. Tax Commission v. Faust
149 N.E. 197 (Ohio Supreme Court, 1925)
Hulbert v. Buehrer
2017 Ohio 844 (Ohio Court of Appeals, 2017)
Bakhtiar v. Saghafi
2018 Ohio 3796 (Ohio Court of Appeals, 2018)
Dunlop v. Ohio Dept. of Job & Family Servs.
2019 Ohio 3632 (Ohio Court of Appeals, 2019)
Ayers v. Cleveland (Slip Opinion)
2020 Ohio 1047 (Ohio Supreme Court, 2020)
Toledo v. State
2022 Ohio 1192 (Ohio Court of Appeals, 2022)
Torbet v. Kilgore
215 N.E.2d 579 (Ohio Supreme Court, 1966)
Morrison v. Steiner
290 N.E.2d 841 (Ohio Supreme Court, 1972)
Hakim v. Kosydar
359 N.E.2d 1371 (Ohio Supreme Court, 1977)
Dresher v. Burt
662 N.E.2d 264 (Ohio Supreme Court, 1996)
Vahila v. Hall
674 N.E.2d 1164 (Ohio Supreme Court, 1997)
State v. Jordan
733 N.E.2d 601 (Ohio Supreme Court, 2000)
Madyda v. Ohio Dept. of Pub. Safety
2024 Ohio 3201 (Ohio Court of Appeals, 2024)
State ex rel. Woods v. Jenkins
2024 Ohio 1753 (Ohio Supreme Court, 2024)
State ex rel. T.B. v. Brown
2025 Ohio 4484 (Ohio Supreme Court, 2025)
State ex rel. Grady v. State Emp. Relations Bd.
1997 Ohio 221 (Ohio Supreme Court, 1997)
Hughes v. Calabrese
2002 Ohio 2217 (Ohio Supreme Court, 2002)

Cite This Page — Counsel Stack

Bluebook (online)
Toledo v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/toledo-v-state-ohioctapp-2026.