Lycan v. Cleveland, 2022 Ohio 4676

Cleveland’s CCO 413.031 authorized camera-based red‑light/speed enforcement and imposed civil fines on the “owner of a vehicle”; the city administratively construed “owner” to include lessees and issued citations to lessees.
Appellees (lessees) received camera-generated citations and paid the civil fines without pursuing the ordinance’s administrative appeal procedure. The ordinance stated that failing to appeal or pay within 21 days "shall be considered an admission."
The city’s administrative process allowed a hearing before the Parking Violations Bureau and then an appeal of the hearing officer’s decision to the common pleas court under R.C. 2506.01.
After Dickson & Campbell (an Eighth District decision holding the ordinance did not apply to lessees), lessees including Lycan filed a class action seeking disgorgement/unjust enrichment of fines paid and declaratory relief. Procedural history included class certification, trial-court judgment for the class, and appeals.
The Ohio Supreme Court held that appellees’ payments (without contest) constituted prior final admissions such that res judicata bars their later unjust‑enrichment claim; it reversed the court of appeals and remanded with instructions to enter judgment for the city.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether payment of camera fines without contest bars a later unjust‑enrichment claim via res judicata	Lycan: Payment was not a judicial determination; res judicata does not apply and unjust‑enrichment relief remains available.	Cleveland: Payment/admission in the available administrative process is a final disposition; claim preclusion bars relitigation.	Held for Cleveland: payments amounted to prior final decisions/admissions; res judicata bars the later unjust‑enrichment suit.
Whether the city waived its res judicata defense by not re‑litigating it after remand	Lycan: City waived the defense by not reasserting it below and by failing to plead it precisely.	Cleveland: The defense was preserved from earlier proceedings and properly raised post‑remand; no waiver.	Held for Cleveland: no waiver; the res judicata issue was preserved and properly reached.
Whether exhaustion of the administrative remedy was required / dispositive here	Lycan: Administrative process was inadequate or futility excused exhaustion; class action allowed.	Cleveland: Administrative hearing was the adequate forum; failure to exhaust forecloses judicial relief.	Court did not decide exhaustion question (declined first proposition); resolved case on res judicata instead.

Dickson & Campbell, L.L.C. v. Cleveland, 181 Ohio App.3d 238 (Eighth Dist. 2009) (held CCO 413.031 did not impose liability on vehicle lessees)
Walker v. Toledo, 143 Ohio St.3d 420 (2014) (recognized municipal authority to create administrative traffic enforcement and described exhaustion requirement)
Hapgood v. Warren, 127 F.3d 490 (6th Cir. 1997) (formulation of four elements for claim preclusion)
Grava v. Parkman Twp., 73 Ohio St.3d 379 (1995) (res judicata/claim‑preclusion principles)
State ex rel. Washington v. Indus. Comm., 112 Ohio St.3d 86 (2006) (res judicata applies to administrative/quasi‑judicial proceedings)