Traditions Tavern, et al. v. City of Columbus

Four bars challenged the validity of a municipal smoke-free law, claiming the law violated the state and federal constitutions. The law prohibited proprietors and employers from allowing smoking in public places and places of employment, specifically exempting smoking within private members-only clubs, and required proprietors and employers to publicize smoking regulations. The Court held that the ordinance did not conflict with state law, was not unconstitutionally vague, did not infringe upon the plaintiffs' due process rights, and did not violate equal protection of the law. The court therefore affirmed the trial court's grant of summary judgment on behalf of the defendants.

Traditions Tavern, et al. v. Columbus, 171 Ohio App. 3d 383, Ohio-6655, Court of Appeals of Ohio, Tenth Appellate District (2006).

  • United States
  • Dec 14, 2006
  • Court of Appeals of Ohio, Tenth Appellate District
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Parties

Plaintiff

  • AD 1400, Inc., d.b.a. Key Club
  • Albert Dowden, Proprietor
  • Beverly Bowles, Proprietor
  • Dimo Kuzmanovski, Proprietor
  • Eugene Hawkins, Proprietor
  • Hazel & Sue, Inc., d.b.a. GJ's Lounge
  • SFKD, Inc., d.b.a. Traditions Tavern
  • Sunrise 967, Inc., d.b.a. Sunset Lounge

Defendant City of Columbus

Legislation Cited

City of Columbus Smoke-free Indoor Air Act of 2004, enacted as Columbus City Code 715

Ohio State Law R.C. 3791.031

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

None

"A statute that provides for the identification and enforcement of no-smoking areas within places of public assembly does not amount to a comprehensive law completely forbidding or permitting smoking inside enclosed public areas. At no point does R.C. 3791.031 provide that smoking must be permitted within places of public assembly. Nor does the statute completely prohibit smoking within public places, although it does allow that the "no smoking area may include the entire place of public assembly." R.C. 3791.031(B). Moreover, the statute does not pertain to all enclosed public spaces. Instead, it applies only to those public places that fall within its definition of a "place of public assembly."4 Conspicuously absent from that definition are the very type of establishments appellants represent. Other examples of enclosed public buildings that are not addressed by R.C. 3791.031 are retail stores, gas stations, and small private businesses. Thus, even if R.C. 3791.031 qualifies as a general law regulating indoor smoking, we could not find that the Columbus smoking ban is in conflict with the statute."