Ohio Rev. Code § 2105.20 (2026)

Waste by tenant for life

✓ current as of May 2026

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Effective:

October 1, 1953

Latest Legislation:

House Bill 1 - 100th General Assembly

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A tenant for life in real property who commits or suffers waste thereto shall forfeit that part of the property, to which such waste is committed or suffered, to the person having the immediate estate in reversion or remainder and such tenant will be liable in damages to such person for the waste committed or suffered thereto.

Notes of Decisions

Cited in 5 cases (1 in the last 5 years), 1962–2023 · leading case: Palmer v. Mossbarger, 2015 Ohio 231 (Ohio Ct. App. 2015).

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Palmer v. Mossbarger, 2015 Ohio 231 (Ohio Ct. App. 2015). · cites it 5× “The complaint alleged that Mossbarger's failure to protect and preserve the property constituted voluntary and permissive waste under R.C. 2105.20 and consequently sought the forfeiture of Mossbarger's life estate interest.”

Folden v. Folden, 188 N.E.2d 193 (Ohio Ct. App. 1962). · cites it 10× “The amended petition was filed under favor of Section 2105.20, Revised Code, in which it is alleged that the parties were former husband and wife; that as a part of a separation agreement executed October 28,1958, the plaintiff deeded to the defendant a life estate in said real…”

Evans v. Willis, 2014 Ohio 1822 (Ohio Ct. App. 2014). · cites it 2× “{¶16} R.C. 2105.20 provides for forfeiture of a life estate as follows: A tenant for life in real property who commits or suffers waste thereto shall forfeit that part of the property, to which such waste is committed or suffered, to the person having the immediate estate in…”

Reel v. Reel, 2014 Ohio 5079 (Ohio Ct. App. 2014). · cites it 2× “{¶14} R.C. 2105.20 governs the forfeiture of life estates.”

Guy Ferrill, III, as of the Est. of Willena T. Ferrill v. Stock Yards Bank & Trust Co., Tr. Under the Will of May T. Doty (Ky. 2023). “Compare Ohio Rev. Code § 2105.20, with KRS 381.350.”

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