Ohio Revised Code

Ohio Rev. Code § 1923.01 (2026)

Jurisdiction in forcible entry and detainer - definitions

✓ current as of May 2026
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(A) As provided in this chapter, any judge of a county or municipal court or a court of common pleas, within the judge's proper area of jurisdiction, may inquire about persons who make unlawful and forcible entry into lands or tenements and detain them, and about persons who make a lawful and peaceable entry into lands or tenements and hold them unlawfully and by force. If, upon the inquiry, it is found that an unlawful and forcible entry has been made and the lands or tenements are detained, or that, after a lawful entry, lands or tenements are held unlawfully and by force, a judge shall cause the plaintiff in an action under this chapter to have restitution of the lands or tenements.

(B) An action shall be brought under this chapter within two years after the cause of action accrues.

(C) As used in this chapter:

(1) "Tenant" means a person who is entitled under a rental agreement to the use or occupancy of premises, other than premises located in a manufactured home park, to the exclusion of others, except that as used in division (A)(6) of section 1923.02 and section 1923.051 of the Revised Code, "tenant" includes a manufactured home park resident.

(2) "Landlord" means the owner, lessor, or sublessor of premises, or the agent or person the landlord authorizes to manage premises or to receive rent from a tenant under a rental agreement, except, if required by the facts of the action to which the term is applied, "landlord" means a park operator.

(3) "Resident" has the same meaning as in section 4781.01 of the Revised Code.

(4) "Residential premises" has the same meaning as in section 5321.01 of the Revised Code, except, if required by the facts of the action to which the term is applied, "residential premises" has the same meaning as in section 4781.01 of the Revised Code.

(5) "Rental agreement" means any agreement or lease, written or oral, that establishes or modifies the terms, conditions, rules, or other provisions concerning the use or occupancy of premises by one of the parties to the agreement or lease, except that "rental agreement," as used in division (A)(13) of section 1923.02 of the Revised Code and where the context requires as used in this chapter, means a rental agreement as defined in division (D) of section 5322.01 of the Revised Code.

(6) "Controlled substance" has the same meaning as in section 3719.01 of the Revised Code.

(7) "School premises" has the same meaning as in section 2925.01 of the Revised Code.

(8) "Sexually oriented offense" and "child-victim oriented offense" have the same meanings as in section 2950.01 of the Revised Code.

(9) "Recreational vehicle" and "mobile home" have the same meanings as in section 4501.01 of the Revised Code.

(10) "Manufactured home" has the same meaning as in section 3781.06 of the Revised Code.

(11) "Manufactured home park" has the same meaning as in section 4781.01 of the Revised Code and also means any tract of land upon which one or two manufactured or mobile homes used for habitation are parked, either free of charge or for revenue purposes, pursuant to rental agreements between the owners of the manufactured or mobile homes and the owner of the tract of land.

(12) "Park operator" has the same meaning as in section 4781.01 of the Revised Code and also means a landlord of premises upon which one or two manufactured or mobile homes used for habitation are parked, either free of charge or for revenue purposes, pursuant to rental agreements between the owners of the manufactured or mobile homes and a landlord who is not licensed as a manufactured home park operator pursuant to Chapter 4781. of the Revised Code.

(13) "Personal property" means tangible personal property other than a manufactured home, mobile home, or recreational vehicle that is the subject of an action under this chapter.

(14) "Preschool or child care center premises" has the same meaning as in section 2950.034 of the Revised Code.

(15) "Minor tenant" means a tenant under eighteen years of age who is not emancipated.

Last updated January 22, 2025 at 2:54 PM

Notes of Decisions
Cited in 64 cases (19 in the last 5 years), 1957–2025 · leading case: Cleveland Bar Ass'n v. Picklo, 96 Ohio St. 3d 195 (Ohio 2002).
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Cleveland Bar Ass'n v. Picklo, 96 Ohio St. 3d 195 (Ohio 2002). · cites it 5× “” R.C. 1923.01. {¶ 13} Here, respondent was the recognized agent of the landlord authorized to bring a forcible entry and detainer action.”
Cleveland Bar Assn. v. Picklo, 2002 Ohio 3995 (Ohio 2002). · cites it 5× “” R.C. 1923.01. {¶13} Here, respondent was the recognized agent of the landlord authorized to bring a forcible entry and detainer action.”
Shaker House, L.L.C. v. Daniel, 2022 Ohio 2778 (Ohio Ct. App. 2022). · cites it 5× “It is undisputed that Shaker House complied with all the requirements of R.C. 1923.01 et seq. for obtaining restitution of the premises and all the local rules of the housing court, except for Loc.”
Seventh Urban, Inc. v. Univ. Circle Prop. Dev., Inc., 423 N.E.2d 1070 (Ohio 1981). · cites it 2× “08 provides that: “No continuance in an action under sections 1923.01 to 1923.14, inclusive, of the Revised Code, shall be granted for a longer period than eight days, unless the defendant, applying therefore gives a bond to the adverse party, with good and sufficient surety, to…”
Adlaka v. Quaranta, 2010 Ohio 6509 (Ohio Ct. App. 2010). · cites it 5× “Finally, forcible entry and detainer actions pursuant to R.C. 1923.01, along with claims for damages arising from a breach of the lease agreement, may be brought by one who, like Karen Adlaka, is a party to the lease agreement and listed as the landlord therein.”
Kuhn v. Griffin, 209 N.E.2d 824 (Ohio Ct. App. 1964). · cites it 4× “But Section 591, Revised Statutes (Section 1909.10, Revised Code), provided that justices of the peace should not have cognizance of any action on contracts for real estate or in actions in which the title to real estate was sought to be recovered, i.”
Miele v. Ribovich, 2000 Ohio 193 (Ohio 2000). “” R.C. 1923.01(A). 3 . In 1988, when the action underlying our decision in Callahan was filed, former Civ.”
Roosevelt Props. Co. v. Kinney, 465 N.E.2d 421 (Ohio 1984). “This precise definition is incorporated in R.C. 1923.01(B)(4), the definitional section of Ohio’s Forcible Entry and Detainer Act.”
Borkowski v. Abood, 884 N.E.2d 7 (Ohio 2008). “R.C. 1923.01 (municipal and county courts, as well as courts of common pleas, have jurisdiction over eviction, or forcible entry and detainer, proceedings).”
Suburban Realty, L.P. v. MD Vape & Tobacco, L.L.C., 2023 Ohio 3198 (Ohio Ct. App. 2023). “R.C. 1923.01(A); Miele v. Ribovich, 90 Ohio St.”
State ex rel. Fischer Asset Mgt., L.L.C. v. Scott, 2023 Ohio 3891 (Ohio Ct. App. 2023). “Also, the facts demonstrate that Fischer complied with all of the requirements of R.C. 1923.01 et seq. for immediate possession of the real property currently occupied by the tenant.”
Ashtabula Cty. Airport Auth. v. Rich, 2014 Ohio 4288 (Ohio Ct. App. 2014). · cites it 2× “{¶16} R.C. 1923.01(A) provides: As provided in this chapter, any judge of a county or municipal court or a court of common pleas, within the judge’s proper area of jurisdiction, may inquire about persons who make unlawful and forcible entry into lands or tenements and detain…”
Show all 64 citing cases →
Ohio Rev. Code § 1923.01(A): 19 cases
Miele v. Ribovich, 2000 Ohio 193 (Ohio 2000). “” R.C. 1923.01(A). 3 . In 1988, when the action underlying our decision in Callahan was filed, former Civ.”
Suburban Realty, L.P. v. MD Vape & Tobacco, L.L.C., 2023 Ohio 3198 (Ohio Ct. App. 2023). “R.C. 1923.01(A); Miele v. Ribovich, 90 Ohio St.”
Ashtabula Cty. Airport Auth. v. Rich, 2014 Ohio 4288 (Ohio Ct. App. 2014). “{¶16} R.C. 1923.01(A) provides: As provided in this chapter, any judge of a county or municipal court or a court of common pleas, within the judge’s proper area of jurisdiction, may inquire about persons who make unlawful and forcible entry into lands or tenements and detain…”
City of Cleveland v. A.J. Rose Mfg. Co., 624 N.E.2d 245 (Ohio Ct. App. 1993).
Fenner v. Parkinson, 590 N.E.2d 339 (Ohio Ct. App. 1990).
Ohio Rev. Code § 1923.01(B)(1): 2 cases
Collins v. Jackson, 517 N.E.2d 269 (Ohio Ct. App. 1986).
Baughman v. Semaan, 505 N.E.2d 643 (Ohio Ct. App. 1986).
Ohio Rev. Code § 1923.01(B)(4): 1 case
Roosevelt Props. Co. v. Kinney, 465 N.E.2d 421 (Ohio 1984). “This precise definition is incorporated in R.C. 1923.01(B)(4), the definitional section of Ohio’s Forcible Entry and Detainer Act.”
Ohio Rev. Code § 1923.01(C)(1): 2 cases
Usha Pillai IRA, L.L.C. v. Roseman, 2023 Ohio 3480 (Ohio Ct. App. 2023).
Turner v. Ormandy, 2022 Ohio 1437 (Ohio Ct. App. 2022).
Ohio Rev. Code § 1923.01(C)(2): 6 cases
Cleveland Bar Ass'n v. Picklo, 96 Ohio St. 3d 195 (Ohio 2002). “” R.C. 1923.01. {¶ 13} Here, respondent was the recognized agent of the landlord authorized to bring a forcible entry and detainer action.”
Cleveland Bar Assn. v. Picklo, 2002 Ohio 3995 (Ohio 2002). “” R.C. 1923.01. {¶13} Here, respondent was the recognized agent of the landlord authorized to bring a forcible entry and detainer action.”
Adlaka v. Quaranta, 2010 Ohio 6509 (Ohio Ct. App. 2010). “Finally, forcible entry and detainer actions pursuant to R.C. 1923.01, along with claims for damages arising from a breach of the lease agreement, may be brought by one who, like Karen Adlaka, is a party to the lease agreement and listed as the landlord therein.”
Henry Cty. Land Reutilization Corp. v. Pelmear, 2022 Ohio 4231 (Ohio Ct. App. 2022).
Tucker v. Pfirsch, 2014 Ohio 3151 (Ohio Ct. App. 2014).
Ohio Rev. Code § 1923.01(C)(5): 1 case
Turner v. Ormandy, 2022 Ohio 1437 (Ohio Ct. App. 2022).
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