Ohio Rev. Code » Chapter 1333
Ohio Revised Code

Ohio Rev. Code § 1333.84 (2026)

Prohibited acts

✓ current as of May 2026
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Effective:
July 30, 2013
Latest Legislation:
Senate Bill 48 - 130th General Assembly
PDF:
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Notwithstanding the terms of any franchise, no manufacturer or distributor engaged in the sale and distribution of alcoholic beverages, or a subsidiary of any such manufacturer, shall:

(A) Fail to act in good faith or without just cause in acting or purporting to act under the terms of a franchise or in cancelling or failing to renew a franchise;

(B) Award an additional franchise for the sale of the same brand within the same sales area or territory. No franchise prohibits a retail permit holder having permits at more than one location from buying from one or more B-2 or B-5 permit holders, even if all permit premises are not located in the same franchise area or territory. Nothing contained in this division shall be construed as modifying the provisions of section 4301.241 of the Revised Code. Nothing contained in this division precludes a manufacturer of wine from awarding a franchise, or requires a manufacturer of wine to award a franchise, for the sale of a new brand to any B-2 or B-5 permit holder.

(C) Require a distributor to submit profit and loss statements, balance sheets, or financial records as a requirement to retain its franchise;

(D) Without reasonable cause, withhold delivery of alcoholic beverages ordered by a distributor, or change or amend a distributor's quota of a manufacturer's product or brand;

(E) Coerce a distributor by any means to participate in or contribute to any local or national advertising fund controlled directly or indirectly by a manufacturer;

(F) Refuse to recognize the rights of surviving partners, shareholders, or heirs and fail to act in good faith in accordance with reasonable standards for fair dealing, with respect to the distributor's right to sell, assign, transfer or otherwise dispose of the distributor's business, in all or in part, except that the distributor shall have no right to sell, assign, or transfer the franchise without the prior consent of the manufacturer, who shall not unreasonably withhold the manufacturer's consent.

(G)(1) On and after the effective date of this amendment, do either of the following:

(a) Award a distribution franchise or territory to itself, to a subsidiary, or to another entity in which it has any financial interest, directly or indirectly, by stock ownership, or through interlocking directors in a corporation, or otherwise, if that franchise, territory, or portion of that territory has been previously awarded, sold, assigned, or transferred to a distributor;

(b) Acquire a franchise or territory if that franchise, territory, or portion of that territory has been previously awarded, sold, assigned, or transferred to a distributor.

(2) Division (G)(1) of this section does not prohibit a manufacturer or subsidiary of a manufacturer from continuing to operate a distribution franchise or distribute alcoholic beverages within a designated territory if prior to the effective date of this amendment the manufacturer either acquired the distribution franchise or territory, or awarded the franchise or territory to itself or a subsidiary.

(3) Division (G)(1) of this section does not, and shall not be construed to, limit the actions that may be taken in accordance with an A-1c permit under section 4303.022 of the Revised Code or a B-2a permit under section 4303.071 of the Revised Code.

(4) Notwithstanding division (G)(1) of this section or any permit requirement under sections 4303.06, 4303.07, 4303.071, 4303.08, 4303.09, and 4303.10 of the Revised Code, if a distribution franchise is canceled or territory is substantially changed by a manufacturer pursuant to either division (A)(1) or (2) of section 1333.85 of the Revised Code, the manufacturer may acquire or award itself the franchise or territory for not longer than one hundred eighty days from the date of cancellation. After the one hundred eighty day period, the manufacturer shall sell or transfer the franchise or territory to a distributor in which the manufacturer does not have any financial interest, directly or indirectly, by stock ownership, or through interlocking directors in a corporation, or otherwise.
Notes of Decisions
Cited in 14 cases (3 in the last 5 years), 1979–2023 · leading case: S. Glazer's Distributors of Ohio, LLC v. Great Lakes Brewing Co., 860 F.3d 844 (6th Cir. 2017).
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S. Glazer's Distributors of Ohio, LLC v. Great Lakes Brewing Co., 860 F.3d 844 (6th Cir. 2017). · cites it 3× “” 1 Ohio Glazer’s asserted that “the pending transaction does not open the Ohio franchise and Great Lakes’ consent is not necessary,” citing Ohio Rev. Code § 1333.84(F) and a district court decision, Jameson Crosse, Inc.”
Beverage Distributors, Inc. v. Miller Brewing Co., 803 F. Supp. 2d 765 (S.D. Ohio 2011). · cites it 6× “Ohio Rev.Code § 1333.84. For example, it requires manufacturers to act in good faith and with just cause, and prohibits manufacturers from adding franchises for the same brand within the territory of an existing distributor of that brand.”
Dayton Heidelberg Distrib. Co. v. Vineyard Brands, Inc., 108 F. Supp. 2d 859 (S.D. Ohio 2000). · cites it 9× “Substantial Likelihood of Success on the Merits Plaintiffs claim that the Defendant’s cancellation of the distributorship relationships violates Ohio Revised Code § 1333.84(A) and § 1333.85, which, inter alia, prohibit a manufacturer from canceling, without just cause, its…”
Excello Wine Co. v. Monsieur Henri Wines, Ltd., 474 F. Supp. 203 (S.D. Ohio 1979). · cites it 5× “O.R.C. §§ 1333.84 and 85. The plaintiff therefore seeks to have the proposed cancellation preliminarily enjoined.”
Diamond Wine & Spirits, Inc. v. Dayton Heidelberg Distrib. Co., 774 N.E.2d 775 (Ohio Ct. App. 2002). “{¶ 3} Under the terms of the Diamond Agreement, and in accordance with R.C. 1333.84(F), C & G was obligated to secure the prior consent of alcoholic beverage manufacturers to the transfer of its franchise right to distribute the manufacturers’ products.”
Jameson Crosse, Inc. v. Kendall-Jackson Winery, Ltd., 917 F. Supp. 520 (N.D. Ohio 1996). · cites it 8× “Important to this controversy is § 1333.84, which provides: [N]o manufacturer or distributor engaged in the sale and distribution of alcoholic beverages .”
Tri-CountyWholesale Distributors, Inc. v. Wine Grp., Inc., 565 F. App'x 477 (6th Cir. 2012). · cites it 2× “On July 2, 2010, TWG sent the Wine Distributors separate notices that it was terminating their franchises under Ohio Rev. Code Ann. §§ 1333.84 and 1333.85, effective September 6, 2010.”
Dayton Heidelberg Distrib. Co. v. Vineyard Brands Inc., 74 F. App'x 509 (6th Cir. 2003). · cites it 4× “Heidelberg alleges (1) that Vineyard had cancelled its franchise without just cause, in violation of Ohio Rev. Code § 1333.84(A), (2) that Vineyard had withheld delivery of wine without reasonable cause, in violation of Ohio Rev.”
Francis A. Bonanno, Inc. v. ISC Wines of California, 564 N.E.2d 1105 (Ohio Ct. App. 1989). · cites it 4× “Allied Wines (“Allied”), against ISC Wines of California sought a preliminary and permanent injunction and damages essentially because ISC terminated the plaintiff’s franchise as a distributor contrary to R.C. 1333.84 and 1333.85 in that it failed to act in good faith and with…”
AB & B, Inc. v. Banfi Prods., Inc., 594 N.E.2d 1151 (Ohio Ct. App. 1991). · cites it 3× “After a two-day bench trial, the trial court found appellant in violation of the Ohio Alcoholic Beverage Franchise Act, R.C. 1333.84 and 1333.85. Subsequently, appellant filed this appeal alleging the following three assignments of error: “1.”
Tri Cnty. Distrib., Inc. v. Canandaigua Wine Co., 1993 Ohio 239 (Ohio 1993). “See R.C. 1333.84(D). While this latter interpretation of the motivation behind R.”
Cavalier Distrib. Co., Inc. v. Lime Ventures, Inc. (S.D. Ohio 2023). · cites it 3× “” Ohio Rev. Code § 1333.84(B). In other words, a franchise confers upon a distributor the exclusive right to sell the “specified brands or products of the manufacturer” within a given turf.”
Show all 14 citing cases →
Ohio Rev. Code § 1333.84(A): 4 cases
Dayton Heidelberg Distrib. Co. v. Vineyard Brands, Inc., 108 F. Supp. 2d 859 (S.D. Ohio 2000). “Substantial Likelihood of Success on the Merits Plaintiffs claim that the Defendant’s cancellation of the distributorship relationships violates Ohio Revised Code § 1333.84(A) and § 1333.85, which, inter alia, prohibit a manufacturer from canceling, without just cause, its…”
Beverage Distributors, Inc. v. Miller Brewing Co., 803 F. Supp. 2d 765 (S.D. Ohio 2011). “Ohio Rev.Code § 1333.84. For example, it requires manufacturers to act in good faith and with just cause, and prohibits manufacturers from adding franchises for the same brand within the territory of an existing distributor of that brand.”
Dayton Heidelberg Distrib. Co. v. Vineyard Brands Inc., 74 F. App'x 509 (6th Cir. 2003). “Heidelberg alleges (1) that Vineyard had cancelled its franchise without just cause, in violation of Ohio Rev. Code § 1333.84(A), (2) that Vineyard had withheld delivery of wine without reasonable cause, in violation of Ohio Rev.”
AB & B, Inc. v. Banfi Prods., Inc., 594 N.E.2d 1151 (Ohio Ct. App. 1991). “After a two-day bench trial, the trial court found appellant in violation of the Ohio Alcoholic Beverage Franchise Act, R.C. 1333.84 and 1333.85. Subsequently, appellant filed this appeal alleging the following three assignments of error: “1.”
Ohio Rev. Code § 1333.84(B): 1 case
Cavalier Distrib. Co., Inc. v. Lime Ventures, Inc. (S.D. Ohio 2023). “” Ohio Rev. Code § 1333.84(B). In other words, a franchise confers upon a distributor the exclusive right to sell the “specified brands or products of the manufacturer” within a given turf.”
Ohio Rev. Code § 1333.84(C): 1 case
Beverage Distributors, Inc. v. Miller Brewing Co., 803 F. Supp. 2d 765 (S.D. Ohio 2011). “Ohio Rev.Code § 1333.84. For example, it requires manufacturers to act in good faith and with just cause, and prohibits manufacturers from adding franchises for the same brand within the territory of an existing distributor of that brand.”
Ohio Rev. Code § 1333.84(D): 4 cases
Dayton Heidelberg Distrib. Co. v. Vineyard Brands Inc., 74 F. App'x 509 (6th Cir. 2003). “Heidelberg alleges (1) that Vineyard had cancelled its franchise without just cause, in violation of Ohio Rev. Code § 1333.84(A), (2) that Vineyard had withheld delivery of wine without reasonable cause, in violation of Ohio Rev.”
Tri Cnty. Distrib., Inc. v. Canandaigua Wine Co., 1993 Ohio 239 (Ohio 1993). “See R.C. 1333.84(D). While this latter interpretation of the motivation behind R.”
AB & B, Inc. v. Banfi Prods., Inc., 594 N.E.2d 1151 (Ohio Ct. App. 1991). “After a two-day bench trial, the trial court found appellant in violation of the Ohio Alcoholic Beverage Franchise Act, R.C. 1333.84 and 1333.85. Subsequently, appellant filed this appeal alleging the following three assignments of error: “1.”
Cavalier Distrib. Co., Inc. v. Lime Ventures, Inc. (S.D. Ohio 2023). “” Ohio Rev. Code § 1333.84(B). In other words, a franchise confers upon a distributor the exclusive right to sell the “specified brands or products of the manufacturer” within a given turf.”
Ohio Rev. Code § 1333.84(F): 3 cases
S. Glazer's Distributors of Ohio, LLC v. Great Lakes Brewing Co., 860 F.3d 844 (6th Cir. 2017). “” 1 Ohio Glazer’s asserted that “the pending transaction does not open the Ohio franchise and Great Lakes’ consent is not necessary,” citing Ohio Rev. Code § 1333.84(F) and a district court decision, Jameson Crosse, Inc.”
Diamond Wine & Spirits, Inc. v. Dayton Heidelberg Distrib. Co., 774 N.E.2d 775 (Ohio Ct. App. 2002). “{¶ 3} Under the terms of the Diamond Agreement, and in accordance with R.C. 1333.84(F), C & G was obligated to secure the prior consent of alcoholic beverage manufacturers to the transfer of its franchise right to distribute the manufacturers’ products.”
Jameson Crosse, Inc. v. Kendall-Jackson Winery, Ltd., 917 F. Supp. 520 (N.D. Ohio 1996). “Important to this controversy is § 1333.84, which provides: [N]o manufacturer or distributor engaged in the sale and distribution of alcoholic beverages .”
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