Ohio Revised Code

Ohio Rev. Code § 2329.03 (2026)

Lien without filing of certificate

✓ current as of May 2026
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Lands and tenements of a judgment debtor shall be bound with a lien for the satisfaction of any judgment of any court of general jurisdiction, including district courts of the United States, within this state, without the filing of the certificate provided for in section 2329.02 of the Revised Code, from the time when the same are seized in execution. Goods and chattels of a judgment debtor shall be bound from the time they are seized in execution.

Notes of Decisions
Cited in 14 cases (1 in the last 5 years), 1961–2022 · leading case: In Re Larotonda, 436 B.R. 491 (Bankr. N.D. Ohio 2010).
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In Re Larotonda, 436 B.R. 491 (Bankr. N.D. Ohio 2010). · cites it 6× “In support of its position, the Defendant relies on O.R.C. § 2329.03 which provides, inter alia: Lands and tenements of a judgment debtor shall be bound with a lien for the satisfaction of any judgment of any court of general jurisdiction, including district courts of the United…”
Wayne Bldg. & Loan Co. v. Yarborough, 228 N.E.2d 841 (Ohio 1967). · cites it 2× “02, Revised Code), or “from the time” when the lands and tenements “are seized in execution” (Section 2329.03, Revised Code). This court can see no reason for distinguishing between the intervening mechanics’ lienors and the mortgagee in Kuhn or the judgment lienor in Second…”
Aristocrat Lakewood Nursing Home v. Dryja (In Re Dryja), 259 B.R. 629 (Bankr. N.D. Ohio 2001). · cites it 2× “O.R.C. § 2329.03. Aristocrat has not shown that it has filed a certificate of judgment, nor that it effected a lien predicated upon the levy of an execution.”
French v. State Farm Mut. Auto. Ins. (In re LaRotonda), 436 B.R. 491 (Bankr. N.D. Ohio 2010). · cites it 6× “In support of its position, the Defendant relies on O.R.C. § 2329.03 which provides, inter alia: Lands and tenements of a judgment debtor shall be bound with a lien for the satisfaction of any judgment of any court of general jurisdiction, including district courts of the United…”
Butz v. Bancohio Nat'l Bank (In Re Toriello), 13 B.R. 425 (Bankr. S.D. Ohio 1981). · cites it 2× “* O.R.C. § 2329.03. O.R.C. § 2329.10 grants priority to writs of execution in the order of their delivery to the sheriff, unless delivery is made on the same day, in which case priority is shared and any proceeds are split pro rata.”
Sinclair Refining Co. v. Chaney, 184 N.E.2d 214 (Ohio Ct. App. 1961). · cites it 2× “) Section 2329.03, Revised Code, provides that “lands and tenements of a judgment debtor shall be bound with a lien.”
Noland v. Turner Constr. Co. (In Re Alpco, Inc.), 62 B.R. 184 (Bankr. S.D. Ohio 1986). “§ 2329.03 (Page 1981) (Emphasis Added). Butz merely applied the statutory provisions of Ohio law.”
Old Phoenix Nat'l Bank of Medina v. Holub (In Re Pendrick), 20 B.R. 972 (Bankr. N.D. Ohio 1982). · cites it 2× “Ohio Revised Code Section 2329.03. The funds held by the Trustee were never seized in execution by the sheriff on behalf of Old Phoenix.”
Hafeez v. Farra (In re Hafeez), 133 B.R. 419 (Bankr. S.D. Ohio 1991). · cites it 2× “” Section 2329.03, Revised Code, provides that “lands and tenements of a judgment debtor shall be bound with a lien.”
Battery One-Stop Ltd. v. Atari Corp. (In re Battery One-Stop Ltd.), 155 B.R. 727 (N.D. Ohio 1993). · cites it 3× “Ohio Rev.Code Ann. § 2329.03 provides that “[gjoods and chattels of a judgment debtor shall be bound from the time they are seized in execution.”
Bonnie Sue Ostrander (Bankr. N.D. Ohio 2022). · cites it 2× “” Ohio Rev. Code § 2329.03. Respondents’ statement in paragraph 46 of the state court complaint that “[t]he Pigott [Judgment] Lien is unsatisfied and constitutes a valid and existing lien and encumbrance against Stone Oak Investments” is misleading at best.”
In re Oliver, 16 Ohio Misc. 290 (S.D. Ohio 1968). · cites it 2× “The gist of all these statutes is born out by Section 2329.03, Revised Code, as to levy of execution, and the levy of execution upon a certificate of judgment provided in Section 2329.”
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