Toney v. City of Dayton

Citations

• 2017 Ohio 5618
• 94 N.E.3d 179

Syllabus

Plaintiffs-appellants assert a facial due process challenge to ordinances enacted by Dayton, Trotwood, and West Carrollton implementing automatic traffic enforcement systems. Under the ordinances, automatic camera stations are installed at selected locations to detect red-light and speed-limit violations. When a violation is detected, a notice of civil liability is mailed to the vehicle's owner. The owner may then pay the monetary penalty or request an administrative hearing to contest the notice. Plaintiffs-appellants assert the ordinances violate Article I, Section 16 of the Ohio Constitution because they fail to provide sufficient due process guarantees. A facial constitutional challenge asserts that an ordinance, on its face and under all circumstances, has no rational relationship to a legitimate governmental purpose. Such a challenge requires proof beyond a reasonable doubt. The ordinances at issue bear a rational relationship to a legitimate governmental function, and are neither unreasonable nor arbitrary. The ordinances, further, provide an appropriate level of procedural due process guarantees in light of their purpose, the private interests at stake and the administrative and fiscal burdens that additional due process protections would impose upon the cities. Judgment affirmed. (Froelich, J., concurring).