Ohio Revised Code

Ohio Rev. Code § 1533.181 (2026)

Immunity

✓ current as of May 2026
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(A) No owner, lessee, or occupant of premises:

(1) Owes any duty to a recreational user to keep the premises safe for entry or use;

(2) Extends any assurance to a recreational user, through the act of giving permission, that the premises are safe for entry or use;

(3) Assumes responsibility for or incurs liability for any injury to person or property caused by any act of a recreational user.

(B) Division (A) of this section applies to the owner, lessee, or occupant of privately owned, nonresidential premises, whether or not the premises are kept open for public use and whether or not the owner, lessee, or occupant denies entry to certain individuals.

Notes of Decisions
Cited in 72 cases (9 in the last 5 years), 1969–2026 · leading case: Combs v. Ohio Dept. of Nat. Resources, Div. of Parks & Rec. (Slip Opinion), 2016 Ohio 1565 (Ohio 2016).
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Combs v. Ohio Dept. of Nat. Resources, Div. of Parks & Rec. (Slip Opinion), 2016 Ohio 1565 (Ohio 2016). · cites it 35× “] Recreational-user statute—R.C. 1533.181—Injury to recreational user from rock thrown by mower is not an injury caused by defect in the premises.”
Ryll v. Columbus Fireworks Display Co., 95 Ohio St. 3d 467 (Ohio 2002). · cites it 15× “On September 5, 2000, the appellate court reversed the trial court, holding that Reynoldsburg was immune from liability pursuant to R.C. 1533.181. It also found that Truro Township was not liable for activities in Huber Park because the park is located in Reynoldsburg.”
Pauley v. City of Circleville, 2013 Ohio 4541 (Ohio 2013). · cites it 26× “” {¶ 8} The trial court granted the city’s motion for summary judgment, finding that the city was immune from suit under R.C. 1533.181. The court of appeals affirmed the trial court’s judgment, with one judge dissenting.”
Ryll v. Columbus Fireworks Display Co., Inc., 2002 Ohio 2584 (Ohio 2002). · cites it 15× “On September 5, 2000, the appellate court reversed the trial court, holding that Reynoldsburg was immune from liability pursuant to R.C. 1533.181. It also found that Truro Township was 2 January Term, 2002 not liable for activities in Huber Park because the park is located in…”
Johnson v. Vill. of New London, 521 N.E.2d 793 (Ohio 1988). · cites it 13× “Thus, lands owned by the state; -political subdivisions and municipalities have never been within the express statutory definition of lands which were subject to this immunity and, accordingly, those governmental units had no direct statutory immunity, pursuant to R.”
Brown v. Vill. of Lincoln Heights, 2011 Ohio 3551 (Ohio Ct. App. 2011). · cites it 16× “and recreational-user immunity under R.C. 1533.181. The trial court denied the village’s motion on the grounds of governmental immunity after concluding that there existed genuine issues of material fact on whether the village was entitled to that immunity.”
LiCause v. City of Canton, 537 N.E.2d 1298 (Ohio 1989). · cites it 17× “R.C. 1533.181 states: “(A) No owner, lessee, or occupant of premises: “(1) Owes any duty to a recreational user to keep the premises safe for entry or use; “(2) Extends any assurance to a recreational user, through the act of giving permission, that the premises are safe for…”
Loyer v. Buchholz, 526 N.E.2d 300 (Ohio 1988). · cites it 14× “The issue presented by this cause is whether, by virtue of R.C. 1533.181, a residential pool owner is immune from a suit for damages resulting from injuries sustained *66 in the pool by a social guest.”
Marrek v. Cleveland Metroparks Bd. of Commissioners, 459 N.E.2d 873 (Ohio 1984). · cites it 8× “II The park district argues that in the event that sovereign immunity has been abolished, it is protected from suit by statutory immunity provided by R.C. 1533.181, which reads in pertinent part: “(A) No owner, lessee, or occupant of premises: “(1) Owes any duty to a…”
Fetherolf v. State, Dept. of Nat. Resources, 454 N.E.2d 564 (Ohio Ct. App. 1982). · cites it 11× “Defendant, therefore, sought dismissal pursuant to R.C. 1533.181 (A)(1) providing in part that the owner of the premises owes no “duty to a recreational user to keep the premises safe for entry or use.”
Fryberger v. Lake Cable Rec. Ass'n, 533 N.E.2d 738 (Ohio 1988). · cites it 8× “I The issue of whether R.C. 1533.181 1 provides immunity to the defendants is controlled by our recent decision in Loyer v.”
Stone v. Northmont City Schs., 2022 Ohio 1116 (Ohio Ct. App. 2022). · cites it 12× “-2- {¶ 1} Appellants Bruce and Gail Stone appeal from the trial court’s judgment granting summary judgment in favor of Appellees Northmont City Schools (“NCS”) and its employee, Lori Barnes, and dismissing the Stones’ complaint for personal injuries based upon recreational user…”
Show all 72 citing cases →
— Ohio Rev. Code § 1533.181(A) — 12 cases
Combs v. Ohio Dept. of Nat. Resources, Div. of Parks & Rec. (Slip Opinion), 2016 Ohio 1565 (Ohio 2016). “] Recreational-user statute—R.C. 1533.181—Injury to recreational user from rock thrown by mower is not an injury caused by defect in the premises.”
Durfor v. W. Mansfield Conservation Club, 2022 Ohio 416 (Ohio Ct. App. 2022).
Marrek v. Cleveland Metroparks Bd. of Commissioners, 459 N.E.2d 873 (Ohio 1984). “II The park district argues that in the event that sovereign immunity has been abolished, it is protected from suit by statutory immunity provided by R.C. 1533.181, which reads in pertinent part: “(A) No owner, lessee, or occupant of premises: “(1) Owes any duty to a…”
Pauley v. City of Circleville, 2013 Ohio 4541 (Ohio 2013). “” {¶ 8} The trial court granted the city’s motion for summary judgment, finding that the city was immune from suit under R.C. 1533.181. The court of appeals affirmed the trial court’s judgment, with one judge dissenting.”
Johnson v. Vill. of New London, 521 N.E.2d 793 (Ohio 1988). “Thus, lands owned by the state; -political subdivisions and municipalities have never been within the express statutory definition of lands which were subject to this immunity and, accordingly, those governmental units had no direct statutory immunity, pursuant to R.”
— Ohio Rev. Code § 1533.181(A)(1) — 16 cases
Combs v. Ohio Dept. of Nat. Resources, Div. of Parks & Rec. (Slip Opinion), 2016 Ohio 1565 (Ohio 2016). “] Recreational-user statute—R.C. 1533.181—Injury to recreational user from rock thrown by mower is not an injury caused by defect in the premises.”
Ryll v. Columbus Fireworks Display Co., 95 Ohio St. 3d 467 (Ohio 2002). “On September 5, 2000, the appellate court reversed the trial court, holding that Reynoldsburg was immune from liability pursuant to R.C. 1533.181. It also found that Truro Township was not liable for activities in Huber Park because the park is located in Reynoldsburg.”
Ryll v. Columbus Fireworks Display Co., Inc., 2002 Ohio 2584 (Ohio 2002). “On September 5, 2000, the appellate court reversed the trial court, holding that Reynoldsburg was immune from liability pursuant to R.C. 1533.181. It also found that Truro Township was 2 January Term, 2002 not liable for activities in Huber Park because the park is located in…”
Pauley v. City of Circleville, 2013 Ohio 4541 (Ohio 2013). “” {¶ 8} The trial court granted the city’s motion for summary judgment, finding that the city was immune from suit under R.C. 1533.181. The court of appeals affirmed the trial court’s judgment, with one judge dissenting.”
Marrek v. Cleveland Metroparks Bd. of Commissioners, 459 N.E.2d 873 (Ohio 1984). “II The park district argues that in the event that sovereign immunity has been abolished, it is protected from suit by statutory immunity provided by R.C. 1533.181, which reads in pertinent part: “(A) No owner, lessee, or occupant of premises: “(1) Owes any duty to a…”
— Ohio Rev. Code § 1533.181(A)(2) — 2 cases
Combs v. Ohio Dept. of Nat. Resources, Div. of Parks & Rec. (Slip Opinion), 2016 Ohio 1565 (Ohio 2016). “] Recreational-user statute—R.C. 1533.181—Injury to recreational user from rock thrown by mower is not an injury caused by defect in the premises.”
Schafer v. Ohio Dept. of Nat. Resources, 2022 Ohio 1829 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 1533.181(A)(3) — 4 cases
Combs v. Ohio Dept. of Nat. Resources, Div. of Parks & Rec. (Slip Opinion), 2016 Ohio 1565 (Ohio 2016). “] Recreational-user statute—R.C. 1533.181—Injury to recreational user from rock thrown by mower is not an injury caused by defect in the premises.”
Ryll v. Columbus Fireworks Display Co., 95 Ohio St. 3d 467 (Ohio 2002). “On September 5, 2000, the appellate court reversed the trial court, holding that Reynoldsburg was immune from liability pursuant to R.C. 1533.181. It also found that Truro Township was not liable for activities in Huber Park because the park is located in Reynoldsburg.”
Ryll v. Columbus Fireworks Display Co., Inc., 2002 Ohio 2584 (Ohio 2002). “On September 5, 2000, the appellate court reversed the trial court, holding that Reynoldsburg was immune from liability pursuant to R.C. 1533.181. It also found that Truro Township was 2 January Term, 2002 not liable for activities in Huber Park because the park is located in…”
Schafer v. Ohio Dept. of Nat. Resources, 2022 Ohio 1829 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 1533.181(A)(l) — 1 case
Mitchell v. Blue Ash, 910 N.E.2d 1118 (Ohio Ct. App. 2009).
— Ohio Rev. Code § 1533.181(B) — 6 cases
Pauley v. City of Circleville, 2013 Ohio 4541 (Ohio 2013). “” {¶ 8} The trial court granted the city’s motion for summary judgment, finding that the city was immune from suit under R.C. 1533.181. The court of appeals affirmed the trial court’s judgment, with one judge dissenting.”
Roberts v. Switzerland of Ohio Local Sch. Dist., 2014 Ohio 78 (Ohio Ct. App. 2014).
Stone v. Northmont City Schs., 2022 Ohio 1116 (Ohio Ct. App. 2022). “-2- {¶ 1} Appellants Bruce and Gail Stone appeal from the trial court’s judgment granting summary judgment in favor of Appellees Northmont City Schools (“NCS”) and its employee, Lori Barnes, and dismissing the Stones’ complaint for personal injuries based upon recreational user…”
Howell v. Buck Creek State Park, 759 N.E.2d 892 (Ohio Ct. App. 2001).
Stiner v. Dechant, 683 N.E.2d 26 (Ohio Ct. App. 1996).
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