Dayton v. State

Citations

• 203 N.E.3d 758
• 2022 Ohio 4412

Syllabus

Regarding the City's photographic traffic enforcement program, R.C. 5747.502, R.C. 1901.20(A)(1), R.C. 1907.02(C), R.C. 4511.096(C), and R.C. 4511.099(A) do not conflict with local Dayton ordinances or violate the Home Rule Amendment, because those provisions do not prohibit municipalities from using cameras to enforce their traffic laws. See Newburgh Hts. v. State, Ohio Slip Opinion No. 2022-Ohio-1642, __ N.E.3d __. The trial court erred when it denied the State's motion for summary judgment and held that the contested statutory provisions in H.B. 62, which require municipalities to file their traffic camera citations with the court, to pay a filing fee to the court, and to receive a reduced amount of state money if they operate a traffic camera program, violate the Home Rule Amendment. Also, the contested provisions in H.B. 62 do not violate the one-subject rule, because Dayton's photo-enforcement program is explicitly related to transportation budgeting, taxation, revenue, and local government funding, and the stated purpose of the H.B. 62 provisions relates to those same issues. As such, the trial court erred when it denied the State's motion for summary judgment on whether the contested provisions in H.B. 62 violated the one-subject rule. Judgment reversed and remanded.