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Ohio Revised Code

Ohio Rev. Code § 2101.23 (2026)

Contempt

✓ current as of May 2026

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Effective:

January 13, 2012

Latest Legislation:

Senate Bill 124 - 129th General Assembly

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The probate judge may keep order in the judge's court and has authority throughout the state to compel performance of any duty incumbent upon any fiduciary appointed by or accounting to the judge. The probate judge may punish any contempt of the judge's authority as that contempt might be punished in the court of common pleas.

If a person neglects or refuses to perform an order or judgment of a probate court, other than for the payment of money, the person is guilty of contempt of court, and the judge shall issue a summons directing the person to appear before the court within two days from the service of the summons and show cause why the person should not be punished for contempt. If it appears to the judge that the person is attempting to avoid the process of the court or is about to leave the county for that purpose, the judge may issue an attachment instead of the summons, commanding the officer to whom it is directed, to bring the person before the judge to answer for contempt. If no sufficient excuse is shown, the person shall be punished for contempt.

Notes of Decisions

Cited in 6 cases (2 in the last 5 years), 1992–2026 · leading case: Dibert v. Carpenter, 2018 Ohio 1054 (Ohio Ct. App. 2018).

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Dibert v. Carpenter, 2018 Ohio 1054 (Ohio Ct. App. 2018). “This is consistent with R.C. 2101.23, which restricts the probate court's power to issue contempt orders by stating that: "If a person neglects or refuses to perform an order or judgment of a probate court, other than for the payment of money , the person is guilty of contempt…”

In re Guardianship of Jadwisiak, 593 N.E.2d 1379 (Ohio 1992). “That power is conferred by R.C. 2101.23, which provides: “The probate judge may keep order in his court and has authority throughout the state to compel performance of any duty incumbent upon any fiduciary appointed by or accounting to him.”

In Re Kinross, 616 N.E.2d 1128 (Ohio Ct. App. 1992). “The court further cited R.C. 2101.23, which provides: “The probate judge may keep order in his court and has authority throughout the state to compel performance of any duty incumbent upon any fiduciary appointed by or accounting to him.”

In re Disqualification of Park, 2024 Ohio 3184 (Ohio 2024). “In the probate court’s April 5 citation, the judge ordered Golub to appear for a hearing and cited R.C. 2101.23, which authorizes a probate judge to punish any contempt of the judge’s authority.”

In Re Guardianship of Brisboy, 640 N.E.2d 908 (Ohio Ct. App. 1994). · cites it 6× “Appellant argues that the probate court’s authority under R.C. 2101.23 to punish for contempt is limited and specifically excludes the power to find him in contempt for his refusal to pay money to the guardian of Joseph Brisboy’s estate.”

In re Est. of Shurman, 2026 Ohio 1343 (Ohio Ct. App. 2026). “05 AND R.C. 2101.23.” {¶16} The appellant’s brief is difficult to follow, and is replete with flawed reasoning and red herrings.”

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