Do federal courts have legal authority to alter or amend the plain meaning of a lawfully-enacted statute of a sovereign state or a lawfully-enacted ordinance of a sovereign municipality that were an exercise of the state or municipality's police powers?

Issue Reserved on Remand if Court Rules for Petitioner on Question 1

A. Did the City of Toledo's ("Respondent") ordinance (TMC § 313.12) and hearing ("Hearing"), under color of law, unconstitutionally force Patrick J. Downey ("Petitioner") to choose between exercising his right to due process of law under the Fourteenth Amendment and his right against self-incrimination under the Fifth Amendment?

Did Parratt v. Taylor, 451 U.S. 527 (1981) provide legal authority for the circuit court to enter judgment against Petitioner, a non-prisoner plaintiff, for failing to exhaust state court remedies when Petitioner's Declaratory Judgment Act complaint alleged violations of his right to due process of law under the Fourteenth Amendment and 42 United States Code ("USC") § 1983?

Issue Reserved on Remand if Court Rules for Petitioner on Questions 1 & 2

A. Did Respondent, under color of law, violate Petitioner's right to due process of law under the Fourteenth Amendment by assessing penalties against Petitioner when TMC § 313.12 did not provide it with legal authority to operate a civil traffic enforcement program that deployed police officers operating mobile cameras and its program exceeded its Home Rule authority under Ohio's Constitution?

Issues Reserved on Remand if Court Rules for Petitioner on Question 2

A. Did Respondent, under color of law, violate Petitioner's right to due process of law by assessing an additional penalty under TMC § 313.12(d)(5) when the penalty, under the facts presented, was not authorized by its ordinance, which Respondent admitted in its appellate brief?

B. Would Respondent, under color of law, violate Petitioner's right to due process of law by towing or immobilizing his vehicle when the action, under the facts presented, was not authorized by its ordinance, which Respondent admitted in its appellate brief?

C. Did the Hearing provided by Respondent under TMC § 313.12 violate, under color of law, Petitioner's right to procedural due process of law?

In light of Respondent's admission that it did not have legal authority to take the actions complained of in the third and fourth issues of Petitioner's declaratory judgment action, did the circuit court have legal authority to grant judgment to Respondent on those issues?

Do federal courts have authority to alter the plain meaning of a state or municipal law?