Ohio Revised Code

Ohio Rev. Code § 1345.03 (2026)

Unconscionable consumer sales acts or practices

✓ current as of May 2026
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(A) No supplier shall commit an unconscionable act or practice in connection with a consumer transaction. Such an unconscionable act or practice by a supplier violates this section whether it occurs before, during, or after the transaction.

(B) In determining whether an act or practice is unconscionable, the following circumstances shall be taken into consideration:

(1) Whether the supplier has knowingly taken advantage of the inability of the consumer reasonably to protect the consumer's interests because of the consumer's physical or mental infirmities, ignorance, illiteracy, or inability to understand the language of an agreement;

(2) Whether the supplier knew at the time the consumer transaction was entered into that the price was substantially in excess of the price at which similar property or services were readily obtainable in similar consumer transactions by like consumers;

(3) Whether the supplier knew at the time the consumer transaction was entered into of the inability of the consumer to receive a substantial benefit from the subject of the consumer transaction;

(4) Whether the supplier knew at the time the consumer transaction was entered into that there was no reasonable probability of payment of the obligation in full by the consumer;

(5) Whether the supplier required the consumer to enter into a consumer transaction on terms the supplier knew were substantially one-sided in favor of the supplier;

(6) Whether the supplier knowingly made a misleading statement of opinion on which the consumer was likely to rely to the consumer's detriment;

(7) Whether the supplier has, without justification, refused to make a refund in cash or by check for a returned item that was purchased with cash or by check, unless the supplier had conspicuously posted in the establishment at the time of the sale a sign stating the supplier's refund policy.

(C) This section does not apply to a consumer transaction in connection with the origination of a residential mortgage.

Notes of Decisions
Cited in 152 cases (35 in the last 5 years), 1976–2026 · leading case: Delahunt v. Cytodyne Tech., 241 F. Supp. 2d 827 (S.D. Ohio 2003).
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Delahunt v. Cytodyne Tech., 241 F. Supp. 2d 827 (S.D. Ohio 2003). · cites it 18× “Ohio Rev.Code § 1345.03. Pursuant to these provisions, Ohio Rev.”
Taylor v. First Resolution Invest. Corp. (Slip Opinion), 2016 Ohio 3444 (Ohio 2016). · cites it 8× “02 and/or § 1345.03.” Kelly v. Montgomery Lynch & Assocs.”
Clayton v. McCary, 426 F. Supp. 248 (N.D. Ohio 1976). · cites it 18× “O.R.C. § 1345.03. See Buckley, Recent Consumer Protection Legislation in Ohio, 22 Cleve.”
Barrett-O'Neill v. LALO, LLC, 171 F. Supp. 3d 725 (S.D. Ohio 2016). · cites it 25× “02); (7) engaged in unconscionable consumer sales acts or practices (O.R.C. § 1345.03); and (8) committed deceptive acts, by charging unauthorized moving expenses,- by failing to provide a written itemized list of specific services rendered, and by failing to provide plaintiff,…”
Edwards v. McCormick, 136 F. Supp. 2d 795 (S.D. Ohio 2001). · cites it 10× “Ohio Rev.Code § 1345.03 dictates: (A) No supplier shall commit an unconscionable act or practice in connection with a consumer transaction.”
Frank v. WNB Grp., L.L.C., 2019 Ohio 1687 (Ohio Ct. App. 2019). · cites it 8× “5 OHIO FIRST DISTRICT COURT OF APPEALS {¶16} Unconscionable acts and practices are prohibited by R.C. 1345.03. R.C. 1345.03(A) generally prohibits suppliers from committing an “unconscionable act or practice” in connection with a consumer transaction.”
Martin v. Gen. Motors Acceptance Corp., 825 N.E.2d 1138 (Ohio Ct. App. 2005). · cites it 12× “Spartan filed its motion for summary judgment, claiming that there was no genuine issue of material fact as to whether it had violated R.C. 1345.03 (unconscionable act) and that as a matter of law, summary judgment should be granted in its favor.”
Karst v. Goldberg, 623 N.E.2d 1348 (Ohio Ct. App. 1993). · cites it 10× “CSPA also prohibits unconscionable acts or practices in connection with a consumer transaction under R.C. 1345.03. R.C. 1345.03(B) provides: “In determining whether an act or practice is unconscionable, the following circumstances shall be taken into consideration: U * * * “(3)…”
Doe v. SexSearch. Com, 502 F. Supp. 2d 719 (N.D. Ohio 2007). · cites it 8× “Unconscionable Acts Plaintiff also alleges Defendants committed unconscionable acts in violation of Ohio Rev.Code § 1345.03 because the contract (a) limited damages to the amount of the contract and (b) provided Defendants a unilateral right to cancel the contract (causes of…”
Thomas v. Nat'l Coll. of Virginia, Inc., 901 F. Supp. 2d 1022 (S.D. Ohio 2012). · cites it 14× “Ohio Rev. Code § 1345.03. Thus, scienter is a necessary element and must be proven in order to find an act unconscionable under ORC § 1345.”
Johnson v. Microsoft Corp., 106 Ohio St. 3d 278 (Ohio 2005). · cites it 2× “02 with R.C. 1345.03: {¶ b} R.C. 1345.02(B): {¶ c} “Without limiting the scope of division (A) of this section, the act or practice of a supplier in representing any of the following is deceptive: {¶ d} “(1) That the subject of a consumer transaction has sponsorship, approval,…”
Baaron, Inc. v. Davidson, 2015 Ohio 4217 (Ohio Ct. App. 2015). · cites it 9× “Davidson did not authorize, and TDP’s false reassurances that the work would fit in her budget, the agreement was unconscionable under Section 1345.03. Motion for a New Trial {¶19} TDP argues that the jury’s damage award was “excessive” under Civil Rule 59(A)(4) because there…”
Show all 152 citing cases →
— Ohio Rev. Code § 1345.03(2) — 1 case
Universal Marble & Granite, L.L.C. v. Gerner, 2014 Ohio 4349 (Ohio Ct. App. 2014).
— Ohio Rev. Code § 1345.03(6) — 2 cases
Marrone v. Philip Morris USA, Inc., 850 N.E.2d 31 (Ohio 2006).
Estep v. Johnson, 704 N.E.2d 58 (Ohio Ct. App. 1998).
— Ohio Rev. Code § 1345.03(A) — 55 cases
Taylor v. First Resolution Invest. Corp. (Slip Opinion), 2016 Ohio 3444 (Ohio 2016). “02 and/or § 1345.03.” Kelly v. Montgomery Lynch & Assocs.”
Frank v. WNB Grp., L.L.C., 2019 Ohio 1687 (Ohio Ct. App. 2019). “5 OHIO FIRST DISTRICT COURT OF APPEALS {¶16} Unconscionable acts and practices are prohibited by R.C. 1345.03. R.C. 1345.03(A) generally prohibits suppliers from committing an “unconscionable act or practice” in connection with a consumer transaction.”
Corcoran v. CVS Health Corp., 169 F. Supp. 3d 970 (N.D. Cal. 2016).
Delahunt v. Cytodyne Tech., 241 F. Supp. 2d 827 (S.D. Ohio 2003). “Ohio Rev.Code § 1345.03. Pursuant to these provisions, Ohio Rev.”
In Re New Motor Vehs. Canadian Exp. Antitrust Litig., 350 F. Supp. 2d 160 (D. Me. 2004).
— Ohio Rev. Code § 1345.03(A)(3) — 1 case
Johnson v. Lincoln Nat'l Life Ins., 590 N.E.2d 761 (Ohio Ct. App. 1990).
— Ohio Rev. Code § 1345.03(B) — 26 cases
Johnson v. Microsoft Corp., 106 Ohio St. 3d 278 (Ohio 2005). “02 with R.C. 1345.03: {¶ b} R.C. 1345.02(B): {¶ c} “Without limiting the scope of division (A) of this section, the act or practice of a supplier in representing any of the following is deceptive: {¶ d} “(1) That the subject of a consumer transaction has sponsorship, approval,…”
Frank v. WNB Grp., L.L.C., 2019 Ohio 1687 (Ohio Ct. App. 2019). “5 OHIO FIRST DISTRICT COURT OF APPEALS {¶16} Unconscionable acts and practices are prohibited by R.C. 1345.03. R.C. 1345.03(A) generally prohibits suppliers from committing an “unconscionable act or practice” in connection with a consumer transaction.”
In Re New Motor Vehs. Canadian Exp. Antitrust Litig., 350 F. Supp. 2d 160 (D. Me. 2004).
United States v. Dish Network LLC, 256 F. Supp. 3d 810 (C.D. Ill. 2017).
Shank v. Charger, Inc., 929 N.E.2d 520 (Ohio Ct. App. 2010).
— Ohio Rev. Code § 1345.03(B)(1) — 17 cases
Barrett-O'Neill v. LALO, LLC, 171 F. Supp. 3d 725 (S.D. Ohio 2016). “02); (7) engaged in unconscionable consumer sales acts or practices (O.R.C. § 1345.03); and (8) committed deceptive acts, by charging unauthorized moving expenses,- by failing to provide a written itemized list of specific services rendered, and by failing to provide plaintiff,…”
Baaron, Inc. v. Davidson, 2015 Ohio 4217 (Ohio Ct. App. 2015). “Davidson did not authorize, and TDP’s false reassurances that the work would fit in her budget, the agreement was unconscionable under Section 1345.03. Motion for a New Trial {¶19} TDP argues that the jury’s damage award was “excessive” under Civil Rule 59(A)(4) because there…”
Culbreath v. Golding Enter., L.L.C., 872 N.E.2d 284 (Ohio 2007).
Clayton v. McCary, 426 F. Supp. 248 (N.D. Ohio 1976). “O.R.C. § 1345.03. See Buckley, Recent Consumer Protection Legislation in Ohio, 22 Cleve.”
Martin v. Gen. Motors Acceptance Corp., 825 N.E.2d 1138 (Ohio Ct. App. 2005). “Spartan filed its motion for summary judgment, claiming that there was no genuine issue of material fact as to whether it had violated R.C. 1345.03 (unconscionable act) and that as a matter of law, summary judgment should be granted in its favor.”
— Ohio Rev. Code § 1345.03(B)(2) — 6 cases
In Re New Motor Vehs. Canadian Exp. Antitrust Litig., 350 F. Supp. 2d 160 (D. Me. 2004).
Clayton v. McCary, 426 F. Supp. 248 (N.D. Ohio 1976). “O.R.C. § 1345.03. See Buckley, Recent Consumer Protection Legislation in Ohio, 22 Cleve.”
Morales v. Walker Motors Sales, Inc., 162 F. Supp. 2d 786 (S.D. Ohio 2000).
Deegan & McGarry v. Med-Cor, 708 N.E.2d 1029 (Ohio Ct. App. 1998).
Martin v. Becker, 2025 Ohio 2356 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 1345.03(B)(3) — 12 cases
Barrett-O'Neill v. LALO, LLC, 171 F. Supp. 3d 725 (S.D. Ohio 2016). “02); (7) engaged in unconscionable consumer sales acts or practices (O.R.C. § 1345.03); and (8) committed deceptive acts, by charging unauthorized moving expenses,- by failing to provide a written itemized list of specific services rendered, and by failing to provide plaintiff,…”
Clayton v. McCary, 426 F. Supp. 248 (N.D. Ohio 1976). “O.R.C. § 1345.03. See Buckley, Recent Consumer Protection Legislation in Ohio, 22 Cleve.”
Walker v. Dominion Homes, Inc., 842 N.E.2d 570 (Ohio Ct. App. 2005).
State Ex Rel. Fisher v. Warren Star Theater, 616 N.E.2d 1192 (Ohio Ct. App. 1992).
State Ex Rel. Fisher v. Am. Courts, Inc., 644 N.E.2d 1112 (Ohio Ct. App. 1994).
— Ohio Rev. Code § 1345.03(B)(4) — 2 cases
State Ex Rel. Fisher v. Warren Star Theater, 616 N.E.2d 1192 (Ohio Ct. App. 1992).
Forsythe Fin., L.L.C. v. Yothment, 2022 Ohio 2798 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 1345.03(B)(5) — 6 cases
Barrett-O'Neill v. LALO, LLC, 171 F. Supp. 3d 725 (S.D. Ohio 2016). “02); (7) engaged in unconscionable consumer sales acts or practices (O.R.C. § 1345.03); and (8) committed deceptive acts, by charging unauthorized moving expenses,- by failing to provide a written itemized list of specific services rendered, and by failing to provide plaintiff,…”
Morales v. Walker Motors Sales, Inc., 162 F. Supp. 2d 786 (S.D. Ohio 2000).
State, Ex Rel. Celebrezze v. Ferraro, 578 N.E.2d 492 (Ohio Ct. App. 1989).
Hunter v. Rhino Shield (S.D. Ohio 2021).
Ewalt v. Gatehouse Media Ohio Holdings II, Inc. (S.D. Ohio 2021).
— Ohio Rev. Code § 1345.03(B)(6) — 8 cases
Shank v. Charger, Inc., 929 N.E.2d 520 (Ohio Ct. App. 2010).
Barrett-O'Neill v. LALO, LLC, 171 F. Supp. 3d 725 (S.D. Ohio 2016). “02); (7) engaged in unconscionable consumer sales acts or practices (O.R.C. § 1345.03); and (8) committed deceptive acts, by charging unauthorized moving expenses,- by failing to provide a written itemized list of specific services rendered, and by failing to provide plaintiff,…”
Hartman v. Asset Acceptance Corp., 467 F. Supp. 2d 769 (S.D. Ohio 2004).
Karst v. Goldberg, 623 N.E.2d 1348 (Ohio Ct. App. 1993). “CSPA also prohibits unconscionable acts or practices in connection with a consumer transaction under R.C. 1345.03. R.C. 1345.03(B) provides: “In determining whether an act or practice is unconscionable, the following circumstances shall be taken into consideration: U * * * “(3)…”
Keel v. Toledo Harley-Davidson/Buell, 920 N.E.2d 1041 (Ohio Ct. App. 2009).
— Ohio Rev. Code § 1345.03(B)(7) — 1 case
Samber v. Mullinax Ford East, 879 N.E.2d 814 (Ohio Ct. App. 2007).
— Ohio Rev. Code § 1345.03(a) — 1 case
The Crossroads Grp., LLC, et al. v. City of Cleveland Heights, Ohio, et al. (N.D. Ohio 2026).
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