## Facts

- The City of Dayton, a charter municipality, enacted a 2002 ordinance authorizing automated red-light enforcement through traffic cameras to conserve police resources and reduce accidents.
- Dayton studied high-accident intersections before installation and reported fewer violation-related accidents after deploying cameras.
- In 2010, Dayton expanded its ordinance to cover automated speed enforcement; cameras captured images/video, and a police officer reviewed evidence before issuing the vehicle owner a civil “notice of liability.”
- In 2014, Ohio enacted Am.Sub.S.B. 342, including:
  - R.C. 4511.093(B)(1), requiring an officer’s presence at the camera location when the violation occurs.
  - R.C. 4511.0912, barring camera-based speeding fines unless speed exceeded the limit by 6 mph (school/park zones) or 10 mph (elsewhere).
  - R.C. 4511.095, requiring a safety study and public-information campaign before using cameras.
- Dayton alleged these provisions conflicted with municipal home-rule authority under Article XVIII, Section 3 of the Ohio Constitution.

## Issues

1. Whether R.C. 4511.093(B)(1)’s officer-presence requirement is a valid “general law” that may preempt a conflicting municipal ordinance under Ohio’s Home Rule Amendment.
2. Whether R.C. 4511.0912’s minimum excess-speed thresholds for camera-based enforcement is a valid “general law” or an unconstitutional constraint on municipal legislative authority.
3. Whether R.C. 4511.095’s safety-study and public-information prerequisites are valid “general laws” or unconstitutional limits on municipal home rule.

## Decision

- The Supreme Court of Ohio reversed the court of appeals and reinstated the trial court’s permanent injunction.
- The court held R.C. 4511.093(B)(1), R.C. 4511.0912, and R.C. 4511.095 unconstitutional as applied to a home-rule municipality because they do not qualify as “general laws.”
- The court concluded each provision restricted municipal police-power decision-making without a demonstrated overriding statewide interest.

## Legal Principles

- A state statute preempts a municipal ordinance under Article XVIII, Section 3 only if the statute is a “general law” and conflicts with the ordinance.
- A statute qualifies as a “general law” only if it: (1) is part of a statewide and comprehensive enactment, (2) applies uniformly statewide, (3) sets forth substantive police/sanitary regulations rather than merely granting or limiting municipal legislative power, and (4) prescribes a rule of conduct upon citizens generally.
- Statutes aimed chiefly at controlling how municipalities exercise police power—rather than prescribing uniform conduct rules for the public—fail the “general law” test and cannot displace conflicting home-rule ordinances.
- Absent an overriding statewide interest, targeted restrictions on municipal enforcement methods impermissibly infringe municipal home-rule authority.

## Conclusion

The court invalidated three statutory limits on municipal traffic-camera programs, ruling they were not “general laws” because they chiefly constrained municipal legislative choices rather than imposing uniform rules of conduct on motorists, and the State did not show an overriding statewide interest sufficient to override home rule.


City of Dayton v. State, 87 N.E.3d 176 (Ohio 2017)