Walker v. Toledo
Annotate this CaseIn 2008, the City of Toledo enacted an ordinance authorizing an automated traffic-law-enforcement system that assesses civil penalties against a vehicle’s owner for speeding and red-light violations. The ordinance further provides that appeals are heard through an administrative process established by the Toledo police department. Appellee received a notice of liability for a traffic violation under the ordinance and paid the civil penalty without pursuing an administrative appeal. Appellee then filed a class-action complaint against the City for unjust enrichment, asserting that the ordinance was unconstitutional. The trial court dismissed the complaint. The Court of Appeals reversed, holding that the ordinance was unconstitutional because it usurped the jurisdiction of the municipal court. The Supreme Court reversed, holding (1) the Ohio Constitution and statutory law do not endow municipal courts with exclusive authority over traffic-ordinance violations; and (2) Ohio municipalities have home rule-authority to impose civil liability on traffic violators through an administrative enforcement system and to establish administrative proceedings that must be exhausted before offenders can pursue judicial remedies.
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