City of Toledo v. Corr. Comm'n of Nw. Ohio
103 N.E.3d 209
| Ohio Ct. App. | 2017Background
- City of Toledo (no municipal jail) and five counties are members of CCNO, a regional jail governed by successive agreements (Fourth and later Fifth Agreement). Toledo reserved 228 beds; Lucas County reserved 203.
- In 2014 Toledo changed charging practices to cite state law rather than city ordinances for many arrests; CCNO’s executive director then adopted a billing rule allocating inmates to the county based on the statute charged (Rule 13). This shifted costs to Lucas County and generated intergovernmental billing disputes.
- CCNO membership adopted a Fifth Amended Agreement reallocating fiscal responsibility for inmates sentenced by municipal courts to the originating municipality; Toledo refused to approve or certify funds for that Agreement.
- Toledo sued, seeking declarations that (1) Lucas County, not Toledo, must pay for incarceration of persons charged/convicted under the Ohio Revised Code, and (2) the Fifth Agreement is not binding on Toledo. Trial court granted Toledo summary judgment on both claims; defendants appealed.
- On appeal, the Sixth District affirmed: it interpreted relevant statutes (R.C. 753.02(A) and R.C. 1905.35) and held the Fifth Agreement is not binding on Toledo due to absence of required fiscal certification (R.C. 5705.41).
Issues
| Issue | Plaintiff's Argument (Toledo) | Defendant's Argument (Commission/County/Sheriff) | Held |
|---|---|---|---|
| Does R.C. 753.02(A) require Toledo to pay costs of prisoners charged/convicted under state law in Toledo courts? | R.C. 753.02(A) imposes duty on municipalities to sustain all persons sentenced or confined, so Toledo must pay for state-law misdemeanants processed in Toledo courts. | R.C. 753.02(A) requires municipalities either to operate a jail or contract with county and to pay for prisoners sentenced by the municipal court, thus Toledo must pay. | No. R.C. 753.02(A) applies to prisoners confined in a municipality’s own prison/station house; Toledo has none, so it has no obligation under that statute. |
| Does R.C. 1905.35 allocate post-conviction incarceration costs for ordinance vs. state-law misdemeanor convictions? | R.C. 1905.35 limits municipal financial responsibility to imprisonment under municipal ordinances; state-law misdemeanants are county responsibility. | Defendants argued statutory placement in "Mayor’s Court" chapter limits scope or that adjudicating court matters. | Held for Toledo: R.C. 1905.35 unambiguously requires municipalities to pay for ordinance imprisonments only; state-law misdemeanants’ postconviction costs are county responsibility. |
| Who pays costs for pretrial detainees housed in county jail (LCCC) pending Toledo Municipal Court cases? | Toledo argued statutory distinctions should still make Toledo responsible. | Defendants conceded that when sheriff has custody in county jail, county bears cost. | Held for defendants (county): Sheriff/county has custody of LCCC detainees and must pay attendant costs (food, medical, bedding, etc.). |
| Is the Fifth Amended Agreement binding on Toledo absent Toledo’s fiscal officer certification under R.C. 5705.41? | Toledo: Fifth Agreement is void as to Toledo because no certificate of fiscal officer (and Toledo’s charter requires same), so Toledo never obligated. | Commission/Sheriff: R.C. 5705.41’s certification requirement does not apply to intergovernmental contracts between subdivisions or is superseded by R.C. Chapter 307 intergovernmental-agreement statutes. | Held for Toledo: R.C. 5705.41’s certification is required; no statutory exception for inter-subdivision contracts exists here, and R.C. 307.19 does not exempt the Fifth Agreement. Without the certificate the Agreement is void as to Toledo. |
Key Cases Cited
- Lang v. Dir., Ohio Dept. of Job & Family Servs., 134 Ohio St.3d 296 (statutory construction reviewed de novo)
- Hulsmeyer v. Hospice of Southwest Ohio, Inc., 142 Ohio St.3d 236 (courts give effect to statutory text to ascertain legislative intent)
- Jacobson v. Kaforey, 149 Ohio St.3d 398 (clear statutory language must be applied as written)
- Myers v. Toledo, 110 Ohio St.3d 218 (express statutory inclusion implies exclusion of other categories)
- St. Marys v. Auglaize Cty. Bd. of Commrs., 115 Ohio St.3d 387 (failure to attach fiscal officer certificate under R.C. 5705.41 invalidates contract)
- In re Application of Columbus S. Power Co., 147 Ohio St.3d 439 (courts may not add or delete statutory language)