Village of Newburgh Heights v. State
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The Supreme Court held that a reallocation of local-government funds regarding fines collected from the use of traffic cameras during the preceding fiscal year, called the "spending setoff," and the "deposit requirement" that municipalities file a civil action to enforce citations issued using traffic cameras to pay an advance deposit in the court are not unconstitutional.
Appellees, municipalities that both operated programs to enforce their traffic laws with cameras, brought this action for a declaratory judgment and for injunction relief asserting that the "spending setoff" and the "deposit requirement" infringed on its municipal home rule powers, in violation of Ohio Const. art. XVIII, 3. Appellees requested a preliminary injunction, which the trial court denied. The court of appeals reversed, ruling that the spending setoff and deposit requirement unconstitutionally penalize municipalities for exercising their home-rule authority to enforce their traffic laws with cameras. The Supreme Court reversed, holding that neither the spending setoff nor the deposit requirement are unconstitutional.
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