Four years after the Supreme Court of Ohio struck down the City of Munroe Falls’ attempt to regulate oil and gas development through zoning, a lower appeals court held that the City and its law director could not sanctioned for attempting to enforce ordinances that required Beck Energy to obtain a zoning certificate and/or variance prior to drilling wells within the city. See State of Ohio, ex rel. Thomas W. Kostoff v. Beck Energy Corp (Apr. 3, 2019). The sanctions motion came in response to the City’s suit for declaratory judgment in 2016 in order to determine whether all municipal zoning matters were preempted by state law—a question the City claimed was left open by the 2015 Supreme Court decision.