Walker v. Toledo, 143 Ohio St. 3d 420, 2014-Ohio-5461

Summary

The Supreme Court of Ohio held that municipalities have home-rule authority to impose civil liability for traffic violations through administrative enforcement systems. It concluded that Ohio Constitution, Article IV, Section 1, and R.C. 1901.20 do not give municipal courts exclusive authority over civil administrative traffic violations. The court reversed the Sixth District Court of Appeals and remanded the case for further proceedings, holding that administrative proceedings must be exhausted before judicial remedies may be pursued.

Holdings

1. Under Ohio Constitution Article XVIII, Sections 3 and 7, municipalities have home-rule authority to impose civil liability on traffic violators through automated administrative enforcement systems.
2. R.C. 1901.20 does not confer exclusive jurisdiction over civil administrative traffic-law violations on municipal courts.
3. Ohio municipalities have home-rule authority to establish presuit administrative proceedings, including administrative hearings, for civil enforcement of traffic ordinances, and those proceedings must be exhausted before offenders or the municipality may pursue judicial remedies.

Questions Presented

1. Whether Toledo's ordinance creating a civil administrative system for automated enforcement of speeding and red-light violations violates Ohio Constitution Article IV, Section 1 or R.C. 1901.20.
2. Whether R.C. 1901.20 gives municipal courts exclusive jurisdiction over civil administrative enforcement of municipal traffic ordinances.
3. Whether Ohio municipalities have home-rule authority to establish presuit administrative proceedings and hearings for civil traffic-law violations that must be exhausted before judicial remedies are pursued.

Disposition

reversed_and_remanded