Petitioners, who had been cited by the City of Myrtle Beach for violating a motorcycle helmet ordinance, sought a judgment declaring (1) that state law preempted the helmet ordinance, and (2) that a later ordinance repealing the administrative hearing system for motorcycle ordinance infractions caused the motorcycle ordinances to fail. The Supreme Court agreed, holding that the helmet ordinance failed under implied field preemption and that it was impliedly repealed by the ordinance repealing the hearing system.
The City of Myrtle Beach enacted a series of motorcycle ordinances in response to motorcycle rally concerns, including one that required helmets and eyewear. The City cited Petitioners for violating the helmet ordinance. Petitioners challenged (1) that state law preempted the ordinance; (2) that the ordinance creating the adjudication system for infractions was so intertwined with the motorcycle ordinances that its repeal caused all the motorcycle ordinances to fail; and (3) that the subsequent system for adjudicating infractions was improper because the municipal court lacked subject matter jurisdiction.
On the preemption issue, the Court stated that state statutes require all riders under 21 to wear helmets and eyewear, whereas the City's ordinance required all riders, regardless of age, to do so. The Court found that the ordinance could not stand, citing the need for uniformity in regulating motorcycle helmets and eyewear. Otherwise riders would have to familiarize themselves and try to comply with numerous ordinances. Such burdens "would unduly limit a citizen's freedom of movement throughout the State." The ordinance therefore failed under the implied preemption doctrine.
On the implied repeal issue, the Court noted that the City initially created an administrative hearing system to handle motorcycle ordinance infractions. The motorcycle ordinances were enacted with the specific condition that they would be enforced by the administrative system. The motorcycle ordinances referencing "administrative infractions" therefore could not be reconciled with a later ordinance repealing the administrative system. The ordinances thus were impliedly repealed when the administrative system was repealed by ordinance.