Toledo v. Ohio
2017 Ohio 215
| Ohio Ct. App. | 2017Background
- In Dec. 2014 the Ohio General Assembly enacted Am.Sub.S.B. No. 342 regulating use of automated traffic photo-monitoring (red light/speed cameras). Toledo sued (Mar. 2015), arguing S.B. 342 violated the Ohio Constitution’s home rule provision.
- On Apr. 27, 2015 the Lucas Cty. Court of Common Pleas found numerous S.B. 342 provisions unconstitutional and entered a permanent injunction against their enforcement. The state appealed and this court later affirmed that decision.
- While the state’s appeal was pending, the legislature passed the biennial budget (Am.Sub.H.B. No. 64) containing provisions that conditioned certain state fund disbursements on municipal compliance with the photo‑monitoring statutes struck down in S.B. 342.
- Toledo moved to enforce its prior injunction and sought an order permanently enjoining enforcement of the budget‑bill provisions as applied to Toledo, arguing the budget provisions were an effort to coerce compliance with statutes already declared unconstitutional.
- The trial court enjoined the state from reducing Toledo’s state funding because enforcement of the budget provisions would violate its earlier injunction and amounted to economic coercion (contempt). The state appealed.
- The Sixth District Court of Appeals affirmed, holding the trial court had continuing jurisdiction to enforce its injunction and did not unlawfully encroach on the legislature’s policymaking role by preventing enforcement of budget provisions that would nullify the court’s order.
Issues
| Issue | Plaintiff's Argument (City of Toledo) | Defendant's Argument (State/Attorney General) | Held |
|---|---|---|---|
| Jurisdiction to enjoin budget‑bill provisions not pleaded originally | Trial court has continuing jurisdiction to enforce its permanent injunction by motion; budget provisions seek to frustrate that injunction | City should have filed a new complaint challenging H.B. 64; court lacked jurisdiction to enjoin laws not in the original complaint | Court: Trial court had continuing jurisdiction to enforce its injunction; assignment not well‑taken |
| Separation of powers — did injunction impermissibly control legislature | Enjoining enforcement of budget provisions was policing compliance with prior court order, not dictating public policy | Injunction intrudes on General Assembly’s role and improperly strikes down new legislation | Court: No separation‑of‑powers violation because court enforced its own order, not making policy |
| Whether budget provisions coerced compliance and constituted contempt | Budget provisions would effectively penalize Toledo for refusing to follow statutes declared unconstitutional — economic coercion and contempt | Budget provisions merely condition discretionary fund distribution; analogous to federal financial incentives to influence state conduct | Court: Budget provisions would force compliance with statutes already enjoined and thus violate the court’s order; contempt/enforcement ruling not an abuse of discretion |
| Entitlement to injunction — was evidence sufficient? | The budget provisions themselves showed a clear conflict with the prior injunction; injunction warranted without further evidentiary showing | City failed to present evidence required for injunctive relief | Court: No abuse of discretion; city showed entitlement because provisions on their face violated the prior injunction |
Key Cases Cited
- Hosta v. Chrysler, 172 Ohio App.3d 654 (2007) (trial court has continuing jurisdiction to enforce a permanent injunction)
- American Motors Corp. v. Huffstutler, 61 Ohio St.3d 343 (1991) (court with in personam jurisdiction may supervise compliance with injunction)
- Wind v. State, 102 Ohio St. 62 (1921) (courts have inherent authority to enforce their orders; enforcement is essential to the judicial function)
- Cicco v. Stockmaster, 89 Ohio St.3d 95 (2000) (declaratory relief claims challenging a statute must be pleaded and Attorney General served to vest jurisdiction under R.C. 2721.12)
- State ex rel. Johnston v. Taulbee, 66 Ohio St.2d 417 (1981) (other branches cannot impede judicial administration of justice)
- Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse‑of‑discretion standard for appellate review)
- Perkins v. Quaker City, 165 Ohio St. 120 (1956) (standard of review for injunctions involves abuse of discretion analysis)
- State ex rel. DeBrosse v. Cool, 87 Ohio St.3d 1 (1999) (courts avoid constitutional questions unless necessary)