Civil Rights & Constitutional Law
Former police lieutenant sues Independence officials for First Amendment retaliation
October 28, 2019
Thursday, July 3, 2025
Leonard Mazzola (Village of Marblehead, Ohio photo)
COLUMBUS, OH – This week, Governor Mike DeWine signed Senate Bill 114 into law, banning law-enforcement agencies in Ohio from imposing traffic-ticket quotas on their officers. The bipartisan bill—backed by the Ohio Police Benevolent Association—passed unanimously in both the Ohio Senate and House.
The bill’s passage is thanks in large part to the advocacy of Chandra Law client Leonard Mazzola, a veteran officer who spent his career with the City of Independence, Ohio. Mazzola strongly opposed the unethical and counterproductive practice of ticket quotas. The quotas pressure officers to issue citations even when unwarranted—just to meet arbitrary numbers.
"Quotas turn officers into revenue generators instead of public servants," Mazzola said. "They create incentives to write tickets regardless of the facts or circumstances—including when a warning would be more appropriate."
Mazzola also warned that traffic-ticket quotas can lead to racially biased policing.
Under the new law—Leonard’s Law—law-enforcement agencies may no longer impose or enforce traffic-ticket quotas. Officers may report violations of the law to the Ohio Attorney General, who must investigate such complaints. If a quota system is found, the attorney general may order the agency to stop.
In October 2019, Chandra Law filed a First Amendment–retaliation lawsuit on Mazzola’s behalf in federal court. The suit named as defendants Independence’s then-mayor Anthony Togliatti, then-police chief Michael Kilbane, law director Gregory J. O’Brien, and the city. And the suit alleged the defendants retaliated against Mazzola for opposing the city's quota system—and for their belief that he had leaked information about it to the media, resulting in negative news coverage.
In November 2020, the federal judge denied the officials’ attempt to dismiss the case, ordering that they stand trial. The court also compelled the defendants to turn over evidence showing they had threatened to falsely brand Mazzola a "Brady cop"—a dishonest officer—to force him out.
This new evidence contradicted defendants' earlier sworn denials.
In 2022, following a federal appellate oral argument that went well for Mazzola, the City of Independence agreed to pay Mazzola nearly $1 million to settle the lawsuit.
Subodh Chandra, Mazzola’s lead counsel, said:
Sometimes, the good guys win. Thanks to Leonard Mazzola’s grit and determination, Leonard’s Law now protects Ohio motorists from unfair policing—and protects honest officers from being forced into unethical conduct.
Cops aren’t canvassers. They shouldn't be judged by how many tickets they write or how much money they bring in. They're supposed to serve the public with integrity. And now, because Len Mazzola stood firm, they can.
Chandra Law has a proven record of fighting for victims of First Amendment retaliation and holding officials accountable for constitutional violations. The firm also helped pioneer litigation over civil damages for criminal acts, securing two landmark Supreme Court of Ohio victories for crime victims.
If you believe your constitutional rights have been violated, contact us to discuss your legal options.
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