## Facts

- The City of Canton’s zoning code long prohibited mobile homes as principal or accessory residential structures.
- In 1998, Canton amended its ordinance to treat “manufactured homes” as “mobile homes,” effectively banning manufactured homes for residential use within city limits.
- The Ohio General Assembly enacted R.C. 3781.184 (effective 1999) addressing manufactured homes.
- R.C. 3781.184(A)–(B) addressed construction and safety standards tied to federal requirements.
- R.C. 3781.184(C) barred political subdivisions from prohibiting or restricting permanently sited manufactured homes in zones where single-family homes are permitted.
- R.C. 3781.184(D) allowed private deed restrictions and restrictive covenants that could prohibit manufactured homes.
- Canton filed a declaratory-judgment action asserting the statute violated the Ohio Constitution’s Home-Rule Amendment and other constitutional provisions.
- The trial court ruled for Canton and invalidated the statute; the court of appeals reversed; the Supreme Court of Ohio accepted discretionary review.

## Issues

1. Whether R.C. 3781.184 qualifies as a “general law” that can limit a municipality’s zoning authority under the Ohio Constitution’s Home-Rule Amendment.
2. Whether R.C. 3781.184(C) and (D) unconstitutionally restrict municipal zoning power by regulating municipalities rather than prescribing generally applicable rules of conduct.
3. Whether remaining constitutional challenges (uniformity, equal protection, due process) required resolution after the home-rule analysis.

## Decision

- The Supreme Court of Ohio affirmed in part and reversed in part the court of appeals.
- The court upheld R.C. 3781.184(A)–(B) as constitutional general laws.
- The court held R.C. 3781.184(C) and (D) unconstitutional under the Home-Rule Amendment.
- As a result, Canton’s zoning authority to prohibit manufactured homes was not displaced by (C) and (D), though uniform statewide safety standards in (A) and (B) remained effective.

## Legal Principles

- Municipalities may adopt and enforce local police regulations, including zoning, unless they conflict with “general laws” enacted by the state.
- For home-rule purposes, a statute is a “general law” only if it:
  - is part of a statewide and comprehensive legislative enactment,
  - applies uniformly throughout the state,
  - sets police, sanitary, or similar regulations (not merely limits municipal legislative power), and
  - prescribes a rule of conduct upon citizens generally.
- Statutory provisions that primarily direct or restrict municipal legislative authority, rather than regulate citizens’ conduct, do not qualify as general laws and cannot preempt municipal home-rule powers.
- Uniform construction and safety standards for manufactured homes may be imposed statewide as valid police-power regulations.

## Conclusion

The court sustained statewide manufactured-housing safety and construction standards but struck down provisions that constrained municipal zoning while permitting similar exclusions through private covenants, holding those parts were not “general laws” and therefore could not override municipal home-rule authority.


Canton v. State, 95 Ohio St. 3d 149, 766 N.E.2d 963 (Ohio 2002)