Lucas Cty. Pit Crew v. Fulton Cty. Dog Warden, 79 N.E.3d 1244

Bosco the pit bull, purchased by Boughton in Fulton County, bit Boughton unprovoked, causing hospitalization; Bosco was quarantined but appellant regained possession before transfer; notices designated Bosco a dangerous dog in Fulton County; hearing requested by appellant; ownership transfer under R.C. 955.11(B) after designation; trial court found Boughton remained owner through designation and upheld designation; appellant challenged jurisdiction and vagueness of the statute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction: who had standing at designation hearing	Lucas County Pit Crew argued ownership/harboring remained with them	Dog Warden asserted Boughton remained owner until transfer under 955.11(B)	Jurisdiction proper; Boughton was owner at inception, Court had jurisdiction.
Vagueness of R.C. 955.11(A)(1)(a)	Argues ‘injury’ undefined, violates due process	Statute sufficiently defines injury via common meaning	Not void-for-vagueness; injury includes non-killing, non-serious harm.
Standing cross-issue (appellee)	Appellant had standing after regaining Bosco on December 26, 2015	Standing limited to harborer/owner at designation time	Cross-issue not necessary to reverse; affirm.

State v. Young, 37 Ohio St.3d 249 (Ohio 1988) (defines common meaning; vagueness standard applied to statutes)
Chicago v. Morales, 527 U.S. 41 (U.S. 1999) (facial vagueness concerns under due process)
Kruppa v. City of Warren, 2009-Ohio-4927 (Ohio 11th Dist. Trumbull 2009) (applies void-for-vagueness framework to ordinances)
Anderson, State v. Anderson, 57 Ohio St.3d 168 (Ohio 1991) (due process vagueness standards for statute)
W. Unity ex rel. Beltz v. Merillat, 2004-Ohio-2682 (Ohio 6th Dist. Williams 2004) (jurisdiction at inception and standing principles)
Perry v. Providence Twp., 63 Ohio App.3d 377 (Ohio 1991) (assignment of error procedure in appeals)