Ohio Revised Code

Ohio Rev. Code § 2111.23 (2026)

Guardian ad litem

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Whenever a ward, for whom a guardian of the estate or of the person and estate has been appointed, is interested in any suit or proceeding in the probate court, such guardian shall in all such suits or proceedings act as guardian ad litem for such ward, except as to suits or proceedings in which the guardian has an adverse interest. Whenever a minor or other person under legal disability, for whom no guardian of the estate or of the person and estate has been appointed, is interested in any suit or proceeding in such court, the court may appoint a guardian or a guardian ad litem. In a suit or proceeding in which the guardian has an adverse interest, the court shall appoint a guardian ad litem to represent such minor or other person under legal disability.

Notes of Decisions
Cited in 8 cases, 1957–2016 · leading case: In re Adoption of Carnes, 457 N.E.2d 903 (Ohio Ct. App. 11th Dist. 1983).
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In re Adoption of Carnes, 457 N.E.2d 903 (Ohio Ct. App. 11th Dist. 1983). · cites it 7× “He argues a guardian ad litem for the minor child was required by R.C. 2111.23 and Civ. R. 17. R.C. 2111.23, in pertinent part, reads: “* * * Whenever a minor or other person under legal disability, for whom no guardian of the estate or of the person and estate has been…”
In re Adoption of Howell, 601 N.E.2d 92 (Ohio Ct. App. 4th Dist. 1991). · cites it 2× “23, which states: “In a suit or proceeding in which the guardian has an adverse interest, the court shall appoint a guardian ad litem to represent such minor or other person under legal disability.”
Lawson v. Lever (In Re Lever), 174 B.R. 936 (Bankr. N.D. Ohio 1991). · cites it 4× “Under the Ohio Revised Code, the duty of a GAL is addressed as follows: R.C. § 2111.23 Guardian ad litem. Whenever a ward, for whom a guardian of the estate or of the person and estate has been appointed, is interested in any suit or proceeding in the probate court, such…”
In re Guardianship of Reynolds, 155 N.E.2d 686 (Ohio Ct. App. 1957). · cites it 6× “The first two sentences of Section 2111.23, Revised Code, refer to the appointment of guardians ad litem for persons under legal disability in proceedings in the Probate Court.”
State ex rel. Florence v. Zitter, 831 N.E.2d 1003 (Ohio 2005). “031, “[i]n connection with an application for the appointment of a guardian for an alleged incompetent, the court may appoint physicians and other qualified persons to examine, investigate, or represent the alleged incompetent, to assist the court in deciding whether a…”
In re Est. of Kahn, 2014-Ohio-4721. · cites it 2× “13-CA-33 7 disability at the time of that proceeding shall be considered to have been a party to that proceeding unless the person was represented in it as provided in section 2111.23 of the Revised Code. Neither the fiduciary nor the fiduciary's surety shall incur any liability…”
In re Guardianship of Carpenter, 2016-Ohio-3389, 66 N.E.3d 272. “R.C. 2111.23. {¶11} Here, Carpenter filed a motion stating her objections to the guardian’s motion to restrict her visitors.”
Albrecht v. Noie, 179 N.E.2d 536 (Ohio Ct. App. 10th Dist. 1960). · cites it 10× “Section 2111.23, Revised Code, provides: “Whenever a minor or other person under legal disability, for whom no guardian of the estate or of the person and estate has been appointed, is interested in any suit or proceeding in such court, the court may appoint a guardian or a…”
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