Springfield v. State (Slip Opinion)
95 N.E.3d 363
| Ohio | 2017Background
- Springfield sued for a declaratory judgment that 2014 Am.Sub.S.B. No. 342 (S.B. 342) is unconstitutional; the trial court rejected the challenge.
- The court of appeals affirmed, holding S.B. 342 "constitutional in its entirety."
- This case was appealed to the Ohio Supreme Court; the majority vacated and remanded in light of Dayton v. State.
- Dayton held R.C. 4511.093(B)(1), 4511.095, and R.C. 4511.0912 unconstitutional, but the decision lacked a majority rationale (fractured court).
- The court of appeals had limited Springfield’s standing on speed-camera provisions because Springfield used only red-light cameras; thus R.C. 4511.0912 (speed thresholds) is not squarely at issue here.
- Justice DeWine (dissenting) argues the remand is unhelpful because Dayton supplies only a bare holding without a controlling rationale and leaves the remaining constitutional questions unresolved; he would prefer this court to decide the remaining issues now.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of R.C. 4511.093(B)(1) (officer presence when traffic camera in use) | Section is unconstitutional under Dayton | Section is constitutional | Remand ordered to reverse as to this provision per Dayton (majority); dissent objects to remanding rather than deciding all issues |
| Constitutionality of R.C. 4511.095 (safety study and public-information prerequisites to traffic camera implementation) | Section is unconstitutional under Dayton | Section is constitutional | Remand ordered to reverse as to this provision per Dayton (majority); dissent objects to remanding rather than deciding all issues |
| Constitutionality of R.C. 4511.0912 (speed thresholds for tickets) | Section unconstitutional (as in Dayton) | Section constitutional; standing contested | Not squarely before court here because of standing limits; Dayton found it unconstitutional but this case did not reach it according to the court of appeals |
| Whether the Ohio Supreme Court should remand for trial-court reconsideration or resolve remaining S.B. 342 issues now | Springfield seeks broad relief declaring S.B. 342 unconstitutional | State seeks affirmation of lower courts; argues remand unnecessary | Majority remanded for reconsideration in light of Dayton; dissent (DeWine, J.) would decide the remaining issues now, criticizing Dayton for lacking an agreed rationale and thus providing little guidance |
Key Cases Cited
- Dayton v. State, 87 N.E.3d 176 (Ohio 2017) (held R.C. 4511.093(B)(1), 4511.095, and 4511.0912 unconstitutional; decision fractured with no single rationale)