Go Syfert

Ohio Revised Code

Ohio Rev. Code § 2317.021 (2026)

Extension of attorney-client privilege in case of dissolved corporation

✓ current as of May 2026

Find cases: SyfertCases citing this section ORCcodes.ohio.gov (official) Justiaon Justia CornellLII Search CasesGoogle Scholar

Effective:

October 12, 2016

Latest Legislation:

House Bill 158 - 131st General Assembly

PDF:

Download Authenticated PDF

(A) As used in division (A) of section 2317.02 of the Revised Code:

"Client" means a person, firm, partnership, corporation, or other association that, directly or through any representative, consults an attorney for the purpose of retaining the attorney or securing legal service or advice from the attorney in the attorney's professional capacity, or consults an attorney employee for legal service or advice, and who communicates, either directly or through an agent, employee, or other representative, with such attorney; and includes an incompetent person whose guardian so consults the attorney in behalf of the incompetent person.

Where a corporation or association is a client having the privilege and it has been dissolved, the privilege shall extend to the last board of directors, their successors or assigns, or to the trustees, their successors or assigns.

This section shall be construed as in addition to, and not in limitation of, other laws affording protection to communications under the attorney-client privilege.

(B) As used in this section and in sections 2317.02 and 2317.03 of the Revised Code, "incompetent" or "incompetent person" means a person who is so mentally impaired, as a result of a mental or physical illness or disability, as a result of an intellectual disability, or as a result of chronic substance abuse, that the person is incapable of taking proper care of the person's self or property or fails to provide for the person's family or other persons for whom the person is charged by law to provide.

Notes of Decisions

Cited in 18 cases (2 in the last 5 years), 1982–2026 · leading case: Biddle v. Warren Gen. Hosp., 86 Ohio St. 3d 395 (Ohio 1999).

Sort: Relevance Newest Treatment

Biddle v. Warren Gen. Hosp., 86 Ohio St. 3d 395 (Ohio 1999). · cites it 5× “According to the hospital, the General Assembly has recognized this principle in R.C. 2317.021 by defining “client” for purposes of the attorney-client privilege statute as a person “who communicates, either directly or through an agent.”

State ex rel. Dann v. Taft, 848 N.E.2d 472 (Ohio 2006). “02(A) does not extend attorney-client privilege to government entities (see R.C. 2317.021, defining ‘client’), the common-law attorney-client privilege recognized in Ohio would apply.”

State ex rel. Leslie v. Ohio Hous. Fin. Agency, 105 Ohio St. 3d 261 (Ohio 2005). “341, Ohio’s whistleblowerprotection statute for state employees.”

Lemley v. Kaiser, 452 N.E.2d 1304 (Ohio 1983). “R.C. 2317.021 states: “As used in division (A) of section 2317.”

State v. McDermott, 651 N.E.2d 985 (Ohio 1995). “” After that decision, the General Assembly adopted R.C. 2317.021, which defines the term “client,” as used in the privilege statute, to include the client’s “agent, employee, or representative.”

Hollingsworth v. Time Warner Cable, 812 N.E.2d 976 (Ohio Ct. App. 2004). “49 {¶ 64} R.C. 2317.021 extends the attorney-client privilege to corporations as clients.”

State v. Today's Bookstore, Inc., 621 N.E.2d 1283 (Ohio Ct. App. 1993). “R.C. 2317.021 defines “client” for the purposes of privileged communications and acts as follows: “ ‘Client’ means a person, firm, partnership, corporation, or other association that, directly or through any representative, consults an attorney for the purpose of retaining the…”

Biddle v. Warren Gen. Hosp., 1999 Ohio 115 (Ohio 1999). · cites it 5× “According to the hospital, the General Assembly has recognized this principle in R.C. 2317.021 by defining “client” for purposes of the attorney-client privilege statute as a person “who communicates, either directly or through an agent.”

Landis v. Hunt, 610 N.E.2d 554 (Ohio Ct. App. 1992). “See, also, R.C. 2317.021. The record indicates that the Landises initiated a meeting with Hunt in May 1982 for the purpose of defining their legal rights arising from the misdiagnosis of Tom Landis’s cancer.”

State v. Bissantz, 444 N.E.2d 92 (Ohio Ct. App. 1982). “02(A) sets forth the attorney-client privilege as follows: “The following persons shall not testify in certain respects: “(A) An attorney, concerning a communication made to him by his client in that relation or his advice to his client; * * *110 “Client” is defined in R.C.…”

State v. Kunzer, 2019 Ohio 2959 (Ohio Ct. App. 2019). “021 (noting the extension of the privilege to attorney’s “agents, employees, and other representatives” has been recognized in cases of dissolved corporations within the definition of the “client” in civil cases). R.C. 2317.02(A) provides a testimonial privilege — i.”

Hamrick v. Union Tp., Ohio, 79 F. Supp. 2d 871 (S.D. Ohio 1999). · cites it 2× “However, Plaintiffs allege that, since Mr. Jones cannot recall any specifics as to what may or may not .”

Show all 18 citing cases →

— Ohio Rev. Code § 2317.021(A) — 3 cases

Clapp v. Mueller Elec. Co., 835 N.E.2d 757 (Ohio Ct. App. 2005).

Zimpfer v. Roach, 2016 Ohio 5176 (Ohio Ct. App. 2016).

Hahn v. Farmakis-King, 2026 Ohio 778 (Ohio Ct. App. 2026).

Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.