Dayton v. State

Citations

• 170 N.E.3d 502
• 2021 Ohio 967

Syllabus

The trial court did not err when it granted the city's motion for summary judgment related to the constitutionality of the following provisions of Am.H.B. No. 62 (H.B. 62): R.C. 4511.093(B)(1), R.C. 5747.502(C), R.C. 5747.502(D), R.C. 5747.502(F), R.C. 4511.096(C), and R.C. 4511.099(A). The trial court correctly found that these were not general laws and violated the city's authority under the Home Rule Amendment. The record established that a conflict existed between the city's local ordinances setting forth its photo traffic enforcement program and these provisions of H.B. 62. The trial court erred when it found that the provisions enacted in H.B. 62 at R.C. 1901.20(A)(1) and R.C. 1907.02(C) violated the one-subject rule and in denying the State's motion for summary judgment related to the constitutionality of those provisions. Judgment affirmed in part, reversed in part, and remanded.