State ex rel. Magsig v. Toledo

Summary

The Supreme Court of Ohio held that R.C. 1901.20(A)(1) grants municipal courts exclusive jurisdiction over civil actions involving violations of state traffic laws or municipal traffic ordinances. Accordingly, the City of Toledo lacked jurisdiction to conduct its own quasi-judicial administrative proceedings concerning red-light and speeding-camera violations. The court granted Susan Magsig's writ of prohibition.

Holdings

1. R.C. 1901.20(A)(1) expressly grants municipal courts exclusive jurisdiction over every civil action concerning a violation of a state traffic law or municipal traffic ordinance, including noncriminal traffic-law adjudications.
2. Toledo lacks jurisdiction to conduct its own quasi-judicial administrative proceedings adjudicating a person's liability for violating a municipal traffic ordinance.
3. A constitutional challenge to other H.B. 62 provisions did not prevent enforcement of R.C. 1901.20(A)(1), because the exclusive-jurisdiction provision was severable from the challenged provisions.
4. A writ of prohibition should issue because Toledo was exercising quasi-judicial power without jurisdiction, and its lack of jurisdiction was patent and unambiguous on the face of R.C. 1901.20(A)(1).

Questions Presented

1. Whether R.C. 1901.20(A)(1), as amended by H.B. 62, gives municipal courts exclusive jurisdiction over civil adjudications of municipal traffic-law violations.
2. Whether Toledo may use its home-rule authority to conduct quasi-judicial administrative proceedings adjudicating liability for red-light and speeding-camera violations.
3. Whether the alleged unconstitutionality of other H.B. 62 provisions prevents enforcement of the exclusive-jurisdiction provision in R.C. 1901.20(A)(1).
4. Whether Magsig was entitled to a writ of prohibition.

Disposition

writ_granted