Wright v. Brice
2021 Ohio 2246
| Ohio Ct. App. | 2021Background
- Village of Brice issued a photo-enforcement speeding ticket for a vehicle operated by Geria Wright on Dec. 13, 2019; an administrative hearing officer found Wright liable on Jan. 22, 2020 and imposed a fine.
- Wright pursued relief in Franklin County Municipal Court, which concluded the ticket/process was noncompliant with then-current law and dismissed the case with prejudice on May 7, 2020.
- The Village appealed the municipal-court judgment to the Tenth District; Wright did not participate in the appeal.
- The Tenth District found a jurisdictional issue: after H.B. 62 and the amendment to R.C. 1901.20, municipal courts have exclusive jurisdiction over civil traffic-law adjudications, so municipal-charter administrative hearings lack authority to adjudicate such matters.
- The court held the administrative hearing officer’s January 22, 2020 order was void for lack of jurisdiction, reversed the municipal-court judgment to the extent it decided the program’s substantive legality, and remanded with instructions to vacate both the municipal judgment and the administrative order.
Issues
| Issue | Plaintiff's Argument (Village of Brice) | Defendant's Argument (Wright) | Held |
|---|---|---|---|
| Whether the municipal court properly declared the Village's photo-enforcement program unlawful and adjudicated the administrative appeal on the merits | Municipal court violated due process by declaring the program unlawful without notice, an evidentiary hearing, or opportunity to be heard | The ticket/process was deficient and the administrative-hearing scheme was not binding; municipal court could relieve the motorist | The appellate court: municipal court lacked subject-matter jurisdiction to decide the program’s substantive validity; reversing that part of the judgment and remanding for limited relief (vacatur) |
| Whether the administrative hearing officer had authority to find liability and impose a fine | Village: administrative hearings under the municipal scheme valid (home-rule authority) | Wright: post–H.B. 62 and Magsig, municipal administrative hearings lack authority to adjudicate civil traffic violations | The appellate court: administrative hearing officer patently lacked jurisdiction under amended R.C. 1901.20; the officer’s order is a nullity and must be vacated |
Key Cases Cited
- Walker v. Toledo, 143 Ohio St.3d 420 (municipal home-rule previously allowed civil enforcement by camera)
- State ex rel. Magsig v. Toledo, 160 Ohio St.3d 342 (amended R.C. 1901.20 vests exclusive jurisdiction over civil traffic violations in municipal courts)
- Patton v. Diemer, 35 Ohio St.3d 68 (Ohio courts have inherent power to vacate void judgments)
- Cupps v. Toledo, 170 Ohio St. 144 (statutory grant of jurisdiction cannot be impaired by municipal charter or ordinance)
- State ex rel. White v. Cuyahoga Metro. Hous. Auth., 79 Ohio St.3d 543 (subject-matter jurisdiction may be raised sua sponte)