Walker v. Toledo (Slip Opinion)
143 Ohio St. 3d 420
Ohio2014Background
- Toledo enacted TMC 313.12 in 2008 establishing automated photo enforcement for red-light and speed violations that imposes civil penalties ($120) on vehicle owners and provides an administrative appeal to a city hearing officer.
- Notices of liability are civil (no criminal stigma or driver's‑license points); failure to pay or appeal within 21 days is deemed an admission.
- Appellee Walker paid a fine and filed a class-action complaint seeking disgorgement, alleging TMC 313.12 usurped municipal‑court jurisdiction (R.C. 1901.20 / Art. IV, §1), was vague, and violated due process.
- Trial court dismissed the complaint under Civ.R. 12(B)(6); the Sixth District reversed, holding the ordinance violated Article IV, Section 1 by divesting municipal‑court jurisdiction.
- The Supreme Court granted discretionary review to decide whether home‑rule municipalities may use pre‑suit civil administrative enforcement (including hearings) for automated traffic violations and whether municipal courts have exclusive jurisdiction.
Issues
| Issue | Walker's Argument | Toledo / Redflex's Argument | Held |
|---|---|---|---|
| Whether a home‑rule municipality may enact civil administrative enforcement for automated traffic violations | City ordinance usurps municipal‑court jurisdiction and conflicts with R.C. 1901.20 / Art. IV, §1 | Municipalities have Article XVIII home‑rule authority to impose complementary civil administrative enforcement (Mendenhall) | Municipalities may adopt civil administrative enforcement of traffic laws under home‑rule authority (affirming Mendenhall) |
| Whether R.C. 1901.20 grants municipal courts exclusive jurisdiction over ordinance violations | "Any ordinance" means every ordinance; municipal court has exclusive jurisdiction over such violations | "Any" does not imply exclusivity; statute does not expressly confer exclusive jurisdiction | R.C. 1901.20 does not confer exclusive jurisdiction on municipal courts for civil administrative enforcement |
| Whether municipalities may establish presuit administrative proceedings and hearings for these civil penalties | Administrative hearings are judicial functions that improperly divest courts and implicate separation of powers | Administrative hearings are permissible exercises of home‑rule authority and complement court jurisdiction; administrative remedies must be exhausted before judicial review | Municipalities may establish presuit administrative proceedings (including hearings); those administrative remedies must be exhausted prior to judicial action |
| Whether due‑process concerns about the operation of the ordinance defeat its validity | Due‑process defects (e.g., inadequate notice/hearing) invalidate the ordinance | Due‑process issues must be addressed under the administrative process and on the facts; Mendenhall did not foreclose procedural scrutiny | Court left due‑process review for the appropriate forum; holding does not resolve specific procedural adequacy here |
Key Cases Cited
- Mendenhall v. Akron, 117 Ohio St.3d 33, 881 N.E.2d 255 (municipal home‑rule authority supports complementary civil administrative enforcement of traffic laws)
- Bazell v. Cincinnati, 13 Ohio St.2d 63, 233 N.E.2d 864 (statutory appeals from local administrative decisions support municipal administrative processes)
- State ex rel. Scott v. Cleveland, 112 Ohio St.3d 324, 859 N.E.2d 923 (administrative disposition of civil traffic‑violation liability can be an adequate remedy)
- State ex rel. Banc One Corp. v. Walker, 86 Ohio St.3d 169, 712 N.E.2d 742 (when legislature intends exclusive jurisdiction, it uses explicit language)
- Cupps v. Toledo, 170 Ohio St. 144, 163 N.E.2d 384 (home‑rule authority does not include power to regulate court jurisdiction)