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Springfield v. State (Slip Opinion)

Citations: 2017 Ohio 8954; 95 N.E.3d 363; 152 Ohio St. 3d 282Docket: 2016-0461

Court: Ohio Supreme Court; December 12, 2017; Ohio; State Supreme Court

Original Court Document: View Document

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The Supreme Court of Ohio vacated the judgment of the Court of Appeals for Clark County and remanded the case to the trial court for the application of the court's holding in Dayton v. State, which deemed certain provisions of Ohio Revised Code (R.C.) unconstitutional. The specific provisions ordered to be addressed by the trial court include R.C. 4511.093(B)(1), mandating law enforcement presence during traffic camera operations, and R.C. 4511.095, requiring a safety study and public information measures before traffic camera implementation. 

The dissenting opinion, authored by Justice DeWine and joined by Justice O’Neill, criticized the majority decision, arguing that the fractured nature of the Dayton ruling provides no clear guidance for the trial court, making it difficult to assess other provisions of the 2014 Am. Sub.S.B. No. 342 that were not addressed. The dissent emphasizes that the lack of a coherent majority opinion in Dayton leaves unresolved constitutional challenges, prolonging uncertainty for Ohio municipalities concerning compliance with the remaining provisions of S.B. 342.

The dissenting justices advocate for an immediate resolution of the outstanding issues rather than further delay. The case was argued on November 21, 2017, and the decision was rendered on December 13, 2017.