State ex rel. Magsig v. Toledo (Slip Opinion), 2020 Ohio 3416

Toledo operates a civil photo-enforcement program (red-light and speed cameras) under Toledo Municipal Code § 313.12 that imposes a $120 civil penalty on vehicle owners for noncriminal traffic violations and treats failure to appeal or pay as admission of liability.
Notices of Liability give vehicle owners 21 days to appeal to an administrative hearing officer established by the municipal police department.
On August 19, 2019, Toledo issued a Notice of Liability to Susan Magsig; she requested a hearing and the city scheduled an administrative hearing for November 19.
Magsig filed an original action in the Ohio Supreme Court seeking a writ of prohibition to prevent Toledo’s administrative hearing, arguing that R.C. 1901.20(A)(1), as amended by 2019 H.B. 62, vests exclusive jurisdiction over noncriminal traffic-law adjudications in municipal courts.
The Ohio Supreme Court granted an alternative writ, received stipulations and briefs, and the Ohio Attorney General filed an amicus brief urging issuance of the writ.
The Court concluded that R.C. 1901.20(A)(1) now grants municipal courts exclusive jurisdiction over civil traffic-law violations and therefore granted a writ of prohibition precluding Toledo’s administrative adjudication.

Issue	Magsig's Argument	Toledo's Argument	Held
Whether municipal administrative hearings may adjudicate noncriminal traffic violations	R.C. 1901.20(A)(1) (as amended) vests municipal courts with exclusive jurisdiction over civil traffic-law violations, precluding city hearings	The statute does not preempt municipal administrative hearings; "exclusive" limits only other courts, not administrative bodies	Held: The amended statute gives municipal courts exclusive jurisdiction; Toledo lacks authority to conduct its own quasi-judicial traffic hearings
Whether Walker v. Toledo bars relief	Walker is inapplicable because it interpreted an earlier version of R.C. 1901.20 that did not confer exclusivity	Walker validated Toledo’s administrative scheme under the earlier statutory text and home-rule authority	Held: Walker addressed a different statutory text; H.B.62 amended R.C. 1901.20 to add exclusivity, so Walker does not control
Whether parts of H.B. 62 being potentially unconstitutional invalidates the exclusive-jurisdiction clause	Even if other H.B.62 provisions are later severed, the exclusive-jurisdiction clause stands and is enforceable	Contends other provisions are unconstitutional, which would undermine enforcement	Held: Any unconstitutional provisions are severable; the exclusive-jurisdiction clause remains enforceable and dispositive

State ex rel. Elder v. Camplese, 40 N.E.3d 1138 (2015) (three-element standard for writ of prohibition)
State ex rel. Sapp v. Franklin Cty. Court of Appeals, 889 N.E.2d 500 (2008) (patent lack of jurisdiction obviates need to show inadequate remedy)
Dept. of Adm. Servs. v. State Emp. Relations Bd., 562 N.E.2d 125 (1990) (writ issues where a tribunal patently lacks jurisdiction)
Walker v. Toledo, 39 N.E.3d 474 (2014) (interpreted R.C. 1901.20 before H.B.62 amended it)
Cupps v. Toledo, 163 N.E.2d 384 (1959) (legislative grant of municipal-court jurisdiction cannot be impaired by local ordinance)
State v. Romage, 7 N.E.3d 1156 (2014) (severability analysis for statutes)