Paschal v. Cuyahoga County Board of Elections

Relators argue that only the charter governs submission of ordinances proposed by initiative petition in the village under R.C. 731.41.1 Respondents argue that both charter and statutes may apply to initiative procedures where the charter incorporates statutes by reference. State ex rel Citizens for a Better Beachwood v. Cuyahoga Cty. Bd. of Elections (1991), 62 Ohio St.3d 167, 580 N.E.2d 1063.2 Specifically, respondents argue that R.C. 731.283 and R.C. 3501.02(F)4 apply because the “charter is silent on the issue of certification by the Clerk.”

Nevertheless, we need not reach these…