Ohio Revised Code

Ohio Rev. Code § 1923.03 (2026)

Judgment not a bar

✓ current as of May 2026
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Judgments under this chapter are not a bar to a later action brought by either party.

Notes of Decisions
Cited in 26 cases (7 in the last 5 years), 1964–2025 · leading case: Mathews v. Cooper, 2021 Ohio 2768 (Ohio Ct. App. 2021).
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Mathews v. Cooper, 2021 Ohio 2768 (Ohio Ct. App. 2021). · cites it 6× “Appellees further argue that they were entitled to recover their moving expenses, storage expenses and attorney fees related to the eviction action in this case rather than the eviction action because (1) “2nd cause claims survive the 1st cause” in a forcible entry and detainer…”
Haney v. Roberts, 720 N.E.2d 101 (Ohio Ct. App. 1998). · cites it 6× “12 to answer the complaint and file any counterclaims, and (3) R.C. 1923.03 specifically provides that forcible entry and detainer actions “are not a bar to later action brought by either party.”
Cerise Capital L.L.C. v. Dewberry, 2022 Ohio 1874 (Ohio Ct. App. 2022). · cites it 4× “Rather, R.C. 1923.03 states, ‘Judgments under this chapter [regarding forcible entry and detainer actions] are not a bar to a later action brought by either party.”
Kuhn v. Griffin, 209 N.E.2d 824 (Ohio Ct. App. 1964). · cites it 8× “Section 1923.03, Revised Code, provides that judgments under such chapter, either in the County Court or in the Common Pleas Court, are not a bar to a later action brought by either party.”
Adams v. Romine, 2019 Ohio 482 (Ohio Ct. App. 2019). · cites it 2× “{¶26} Appellant is correct is her assertion that, pursuant to R.C. 1923.03, judgments under forcible entry and detainer “are not a bar to a later action brought by either party.”
Hamilton Brownfields Redevelopment, LLC v. Duro Tire & Wheel, 806 N.E.2d 1039 (Ohio Ct. App. 2004). · cites it 2× “{¶ 14} R.C. Chapter 1923 governs forcible entry and detainer actions and provides that “[¿judgments under this chapter are not a bar to a later action brought by either party.”
Dennis v. Morgan, 732 N.E.2d 391 (Ohio 2000). “Rather, R.C. 1923.03 states, “Judgments under this chapter [regarding forcible entry and detainer actions] are not a bar to a later action brought by either party.”
Namenyi v. Tomasello, 2014 Ohio 4509 (Ohio Ct. App. 2014). “Pursuant to R.C. 1923.03 forcible entry and detainer judgments do not bar a tenant from bringing a later action between the same parties growing out of the same subject matter; however, such judgments do bar “relitigation of issues that were actually and necessarily decided in…”
Crossings Dev. Ltd. P'ship v. H.O.T., Inc., 645 N.E.2d 159 (Ohio Ct. App. 1994). “This is doubly true in regard to forcible entry and detainer actions because, pursuant to R.C. 1923.03, a judgment in a forcible entry and detainer action is not a bar to later actions brought by either party.”
Fodor v. First Nat'l Supermarkets, Inc., 589 N.E.2d 17 (Ohio 1992). “Is this in the best interest of judicial economy? I think not! R.C. 1923.03 indicates that even if Fodor loses in a forcible entry and detainer action, he may still file an action comparable to the one now before us.”
Soliel Tans, L.L.C. v. Timber Bentley Coe, L.L.C., 2019 Ohio 4889 (Ohio Ct. App. 2019). “Because a forcible entry and detainer action is a summary proceeding, R.C. 1923.03 provides that “[j]udgments under this chapter are not a bar to a later action brought by either party.”
Reck v. Whalen, 682 N.E.2d 721 (Ohio Ct. App. 1996). “As the Recks note in their brief, in providing a fast, effective relief for landlords seeking restitution of premises, R.C. 1923.03 provides as follows: “Judgments under this chapter are not a bar to a later action brought by either party.”
Show all 26 citing cases →
— Ohio Rev. Code § 1923.03(C) — 1 case
Hometown Apts., L.L.C. v. Hoffa, 2022 Ohio 2707 (Ohio Ct. App. 2022).
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