Ohio Trucking Assn. v. Charles
134 Ohio St. 3d 502
| Ohio | 2012Background
- Plaintiffs seek to invalidate R.C. 4509.05(A) amended by Am.Sub.H.B. No. 2 (2009) as violative of Ohio Constitution Article XII, Section 5a.
- The statute requires a $5 fee for certified abstracts of driving records, with specified allocations to various state funds.
- Plaintiffs purchase over five million certified abstracts annually and argue most information is publicly available for free.
- Trial court granted injunctive relief and found part of the fee is spent in non-allowed ways under Section 5a.
- Court of Appeals affirmed standing but upheld the constitutionality finding for the fees as related to highway registration and use.
- The Supreme Court reverses, holding certified-abstract fees are not sufficiently related to registration, operation, or use of vehicles on public highways.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Are certified-abstract fees related to vehicle registration/operation/use? | Charles asserts fees fund non-highway purposes. | Charles contends fees relate to registration/operation/use. | No; fees are not related to registration, operation, or use. |
| Do plaintiffs have standing to challenge the statute? | Plaintiffs suffer increased costs from the amended fee and have standing as associations. | State agencies argue lack of direct injury distinct from the public. | Plaintiffs have standing to challenge the statute. |
| How should 'relating to' be interpreted in Article XII, Section 5a for this context? | Relating to should be read broadly to cover costs tied to motor-vehicle regulation. | Relating to is elastic; should be interpreted to reflect the statute’s objectives. | Notably broad; the Court adopts objective-based analysis and finds the fee not sufficiently related. |
Key Cases Cited
- Knox Cty. Bd. of Commrs. v. Knox Cty. Engineer, 109 Ohio St.3d 353 (2006-Ohio-2576) (limits on 5a expenditures to highway-related purposes)
- Grandle v. Rhodes, 169 Ohio St. 77 (1959) (5a interpretation framework, highway-related revenues)
- State ex rel. Keller v. Forney, 108 Ohio St.463 (1923) (strict construction of exceptions to revenue powers)
- State ex rel. Maurer v. Sheward, 71 Ohio St.3d 513 (1994) (definition of statutory terms and ordinary meaning)
- New York State Conference of Blue Cross & Blue Shield Plans v. Travelers Ins. Co., 514 U.S. 645 (1995) (interpretation of 'relate to' in federal context)
- Ohio Academy of Trial Lawyers v. Sheward, 86 Ohio St.3d 451 (1999) (standing and judicial review principles)
- Hunt v. Washington State Apple Advertising Comm., 432 U.S. 333 (1977) (standing and injury-in-fact considerations; broad interpretation guidance)
- Ohio Contractors Assn. v. Bicking, 71 Ohio St.3d 318 (1994) (associational standing and public-interest litigation)