Columbus v. Kotevski, 2018 Ohio 5105

Defendant Jovan M. Kotevski was cited by Columbus police for making a U‑turn on Dec. 22, 2017 in violation of Columbus City Code (C.C.C.) 2131.12(a), which generally prohibits U‑turns within city limits.
Officer observed the vehicle parked facing north on High Street, make a U‑turn from a parking spot, then proceed south; defendant was stopped and charged.
Defendant pleaded not guilty and raised a constitutional challenge at a bench trial, arguing the city ordinance conflicts with Ohio traffic law and the Uniformity Clause.
Trial court rejected the constitutional challenge and found defendant guilty; defendant appealed to the Tenth District Court of Appeals.
The central legal question was whether C.C.C. 2131.12 conflicts with state law (primarily R.C. 4511.37 and R.C. 4511.06) and therefore is preempted under the Home Rule Amendment and uniformity requirements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Columbus's blanket ban on U‑turns (C.C.C. 2131.12) conflicts with Ohio law	City: no conflict; ordinance does not permit what state law forbids and is a valid exercise of local police power	Kotevski: R.C. 4511.37 makes U‑turns generally lawful except in specified circumstances; R.C. 4511.06 requires uniformity so municipal ban conflicts with state law	Court: no conflict; ordinance and state statute are reconcilable and municipal ban stands

Dayton v. State, 151 Ohio St.3d 168 (2017) (Home Rule analysis: ordinances yield to general state laws when ordinance is police power, statute is general, and conflict exists)
Cincinnati v. Baskin, 112 Ohio St.3d 279 (2006) (conflict exists only if ordinance permits what statute forbids or vice versa)
Village of Struthers v. Sokol, 108 Ohio St. 263 (1923) (articulated test for conflict between ordinances and general laws)
Mendenhall v. Akron, 117 Ohio St.3d 33 (2008) (clarified three‑part test for ordinance/statute conflict under Home Rule)