State v. Eberhart, 2014 Ohio 3259

Jason A. Eberhart was charged in two related Miamisburg Municipal Court cases with misdemeanors for failing to display a license plate (R.C. 4503.21) after police observed him driving without a plate on two occasions (one in Miamisburg, one in Miami Township).
On each occasion an officer stopped Eberhart, issued an Ohio Uniform Traffic Ticket (complaint and summons), and the ticket stated it was personally served on him.
At arraignment Eberhart refused to plead and repeatedly contested the trial court’s personal jurisdiction, claiming status as a “common-law citizen” and asserting he was domiciled in Ohio but not a resident.
The trial court entered a not‑guilty plea for him, rejected his jurisdictional challenges, and proceeded to a bench trial after Eberhart clarified he was contesting only personal (not territorial or subject‑matter) jurisdiction.
Based on officer testimony and the issued traffic tickets, the trial court found Eberhart guilty on both counts and sentenced him; Eberhart appealed claiming the court lacked personal jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Miamisburg Municipal Court had personal jurisdiction over Eberhart	Service of process was properly effected by officers issuing and personally serving Ohio Uniform Traffic Tickets, giving the court jurisdiction	Eberhart argued the court lacked personal jurisdiction (claimed non‑resident/common‑law citizen status) and that proceedings were administrative, not criminal	Court held personal jurisdiction was acquired by personal service of the traffic tickets and overruled Eberhart’s challenge

Maryhew v. Yova, 11 Ohio St.3d 154 (Ohio 1984) (recognizing that personal jurisdiction may be acquired by service of process)