Ohio Revised Code

Ohio Rev. Code § 1345.28 (2026)

Deceptive acts or practices

✓ laws through the 2026 session (checked Sept. 2026)
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Failure to comply with sections 1345.21 to 1345.27 of the Revised Code constitutes a deceptive act or practice in connection with a consumer transaction in violation of section 1345.02 of the Revised Code.

Notes of Decisions
Cited in 13 cases (5 in the last 5 years), 1985–2026 · leading case: Dillon v. Farmers Ins. of Columbus, Inc. (Slip Opinion), 2015-Ohio-5407, 47 N.E.3d 794.
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Dillon v. Farmers Ins. of Columbus, Inc. (Slip Opinion), 2015-Ohio-5407, 47 N.E.3d 794. · cites it 3× “In R.C. 1345.28 and 1345.48, enacted in 1974 and 1976 respectively, the legislature stated that failure to comply with the sections simply “constitutes a deceptive act or practice in connection with a consumer transaction.”
Cartwright v. Beverly Hills Floors, 2013-Ohio-2266. · cites it 3× “{¶27} R.C. 1345.28 provides: “Failure to comply with sections 1345.”
Hanlin v. Ohio Builders & Remodelers, Inc., 196 F. Supp. 2d 572 (S.D. Ohio 2001). · cites it 2× “R.C. § 1345.28. A “home solicitation sale” is defined as follows: [A] sale of consumer goods or services in which the seller or a person acting for the seller engages in a personal solicitation of the sale at a residence of the buyer, including solicitations in response to or…”
Griffin Contracting & Restoration v. McIntyre, 2018-Ohio-3121, 107 N.E.3d 22. “{¶ 27} We note that the failure to comply with the HSSA constitutes a deceptive act or practice in connection with a consumer transaction in violation of the CSPA. R.C.”
Smaldino v. Larsick, 630 N.E.2d 408 (Ohio Ct. App. 11th Dist. 1993). “R.C. 1345.28. Second, appellant argues in her brief that “appellee’s representations that the furnace had to be replaced, when, in fact, it was capable of repair, was violative of O.”
Orion Mgt., Inc. v. Kaeka, 2025-Ohio-1047, 269 N.E.3d 483. · cites it 2× “), citing R.C. 1345.28. The trial court determined, as a matter of law, that the CSPA did not apply to the Contract.”
Santos v. Buckeye 5, L.L.C., 2023-Ohio-3602, 225 N.E.3d 514. “) {¶41} R.C. 1345.28 states: “Failure to comply with sections 1345.”
J & D Rack Co. v. Kreimer, 2011-Ohio-2358, 957 N.E.2d 39. “See R.C. 1345.28 ("Failure to comply with sections 1345.”
Ostigny v. France, 2025-Ohio-4885. · cites it 2× “” R.C. 1345.28. 3. The Interplay Between Remedies Under the HSSA and the CSPA {¶55} As indicated above, “[w]hen a supplier has committed an unfair or deceptive act in connection with a consumer transaction, the consumer may ‘rescind the transaction or recover the consumer’s…”
Bramley's Water Conditioning v. Hagen, 501 N.E.2d 38 (Ohio Ct. App. 11th Dist. 1985). “This was a deceptive sales act, R.C. 1345.28, in violation of R.C. 1345.02.”
Grinder v. Schaaf, 2025-Ohio-4723. “07 (R.C. 1345.28). Brown v. Martinelli, 66 Ohio St.”
Horvath v. Waite, No. 18-03061 (Bankr. N.D. Ohio Sept. 27, 2019). “Again, the only claim in Horvath’s state court complaint that even approaches the vicinity of fraud is the claim brought under the Ohio Consumer Sales Practices Act.”
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