Ohio Rev. Code » Chapter 2329
Ohio Revised Code

Ohio Rev. Code § 2329.661 (2026)

Certain claims not exempted

✓ current as of May 2026
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Effective:
March 27, 2013
Latest Legislation:
House Bill 479 - 129th General Assembly
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(A) Division (A)(1) of section 2329.66 of the Revised Code does not:

(1) Extend to a judgment rendered on a mortgage executed, or security interest given on real or personal property by a debtor or to a claim for less than four hundred dollars for manual work or labor;

(2) Impair the lien, by mortgage or otherwise, of the vendor for the purchase money of real or personal property that the debtor or a dependent of the debtor uses as a residence or the lien of a mechanic or other person, under a statute of this state, for materials furnished or labor performed in the erection of a dwelling house on real property;

(3) Affect or invalidate any mortgage on any real property or any lien created by such a mortgage;

(4) Impair a lien for the payment of taxes, debts, or other obligations owed to this state or any agency or political subdivision of this state;

(5) Extend to a judgment rendered against a debtor for tortious operation of a motor vehicle by the debtor that results in injury, death, or loss to person or property if that injury, death, or loss was caused at a time when the debtor failed to maintain proof of financial responsibility as defined in section 4509.01 of the Revised Code.

(B) No promise, agreement, or contract shall be made or entered into that would waive the exemption laws of this state, and every promise, agreement, or contract insofar as it seeks to waive the exemption laws of this state is void.

(C) Section 2329.66 of the Revised Code does not affect or invalidate any sale, contract of sale, conditional sale, security interest, or pledge of any personal property, or any lien created thereby.
Notes of Decisions
Cited in 38 cases (3 in the last 5 years), 1980–2026 · leading case: Cox v. Blazer Fin. Servs., Inc. (In Re Cox), 4 B.R. 240 (Bankr. S.D. Ohio 1980).
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Cox v. Blazer Fin. Servs., Inc. (In Re Cox), 4 B.R. 240 (Bankr. S.D. Ohio 1980). · cites it 12× “Ohio Revised Code Section 2329.661(3)(c) states: “Section 2329.”
Curry v. Assocs. Fin. Servs. (In Re Curry), 5 B.R. 282 (Bankr. N.D. Ohio 1980). · cites it 8× “This contradicts the language of O.R.C. 2329.661(C). However, it will be shown that the Federal bankruptcy statute, 11 U.”
In Re Hill, 4 B.R. 310 (Bankr. N.D. Ohio 1980). · cites it 6× “This contradicts the language of O.R.C. 2329.661(C). However it will be shown that the Federal bankruptcy statute, 11 U.”
Panesky v. CIT Fin. Servs. (In Re Panesky), 5 B.R. 201 (Bankr. N.D. Ohio 1980). · cites it 14× “However, the Ohio Legislature has further limited its application and definition of that exemption by enacting Ohio Revised Code Section 2329.661. Section 2329.661(C) provides: “(C) Section 2329.”
Fisher v. Liberty Loan Corp. (In Re Fisher), 6 B.R. 206 (Bankr. N.D. Ohio 1980). · cites it 8× “*209 § 522(f), is superior to the state exemption statute, Ohio Rev.Code § 2329.661(C). 11 U.S.C. § 522 (f) provides that: Notwithstanding any waiver of exemptions, the debtor may avoid the fixing of a lien on an interest of the debtor in property to the extent that such lien…”
In Re Wycuff, 332 B.R. 297 (Bankr. N.D. Ohio 2005). · cites it 3× “shall not include the amount of any lien otherwise valid pursuant to section 2329.661 of the Revised Code.” The relevant portion of § 2329.”
In Re Smith, 92 B.R. 287 (Bankr. S.D. Ohio 1988). · cites it 4× “O.R.C. § 2329.661 provides that certain claims are not exempted from judgment.”
Storer v. Thorp Credit Inc. (In Re Storer), 13 B.R. 1 (Bankr. S.D. Ohio 1980). · cites it 8× “But there is nothing in the Bankruptcy Code which authorizes a state to pass a law such as O.R.C. 2329.661(3)(c) which would be effective in bankruptcy to defeat the purpose of 11 U.”
In Re Hill, 11 B.R. 217 (Bankr. S.D. Ohio 1981). · cites it 6× “” The liens otherwise valid pursuant to Ohio Rev.Code § 2329.661, in this instance, are the first and second mortgages on the property in question.”
Phillips v. Household Fin. Corp. (In re Phillips), 13 B.R. 811 (Bankr. N.D. Ohio 1981). · cites it 12× “Defendants and plaintiffs agreed to submit the matter to the court upon the following agreed facts.”
In Re Richardson, 216 B.R. 206 (Bankr. S.D. Ohio 1997). · cites it 4× “” Ohio Rev.Code Ann. § 2329.661 (Anderson 1997).”
Curry v. Assocs. Fin. Servs., 11 B.R. 716 (N.D. Ohio 1981). · cites it 3× “Any contractual right in property under a security agreement is protected in state court under Ohio Rev.Code § 2329.661(C) (Page Supp.1980).”
Show all 38 citing cases →
— Ohio Rev. Code § 2329.661(3)(c) — 2 cases
Cox v. Blazer Fin. Servs., Inc. (In Re Cox), 4 B.R. 240 (Bankr. S.D. Ohio 1980). “Ohio Revised Code Section 2329.661(3)(c) states: “Section 2329.”
Storer v. Thorp Credit Inc. (In Re Storer), 13 B.R. 1 (Bankr. S.D. Ohio 1980). “But there is nothing in the Bankruptcy Code which authorizes a state to pass a law such as O.R.C. 2329.661(3)(c) which would be effective in bankruptcy to defeat the purpose of 11 U.”
— Ohio Rev. Code § 2329.661(3)(e) — 1 case
Cox v. Blazer Fin. Servs., Inc. (In Re Cox), 4 B.R. 240 (Bankr. S.D. Ohio 1980). “Ohio Revised Code Section 2329.661(3)(c) states: “Section 2329.”
— Ohio Rev. Code § 2329.661(A) — 1 case
Mut. Loan & Sav. Co. v. Warren (In re Davis), 12 B.R. 15 (Bankr. S.D. Ohio 1981).
— Ohio Rev. Code § 2329.661(A)(1) — 1 case
Dailey v. Miller, 2024 Ohio 1340 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2329.661(A)(2) — 1 case
Mut. Loan & Sav. Co. v. Warren (In re Davis), 12 B.R. 15 (Bankr. S.D. Ohio 1981).
— Ohio Rev. Code § 2329.661(A)(3) — 1 case
Marietta v. Verhovec, 2024 Ohio 1184 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2329.661(A)(4) — 2 cases
In re Gokay, 535 B.R. 758 (Bankr. S.D. Ohio 2015).
Weese v. Dalton, 2026 Ohio 537 (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2329.661(C) — 17 cases
Curry v. Assocs. Fin. Servs. (In Re Curry), 5 B.R. 282 (Bankr. N.D. Ohio 1980). “This contradicts the language of O.R.C. 2329.661(C). However, it will be shown that the Federal bankruptcy statute, 11 U.”
Panesky v. CIT Fin. Servs. (In Re Panesky), 5 B.R. 201 (Bankr. N.D. Ohio 1980). “However, the Ohio Legislature has further limited its application and definition of that exemption by enacting Ohio Revised Code Section 2329.661. Section 2329.661(C) provides: “(C) Section 2329.”
Fisher v. Liberty Loan Corp. (In Re Fisher), 6 B.R. 206 (Bankr. N.D. Ohio 1980). “*209 § 522(f), is superior to the state exemption statute, Ohio Rev.Code § 2329.661(C). 11 U.S.C. § 522 (f) provides that: Notwithstanding any waiver of exemptions, the debtor may avoid the fixing of a lien on an interest of the debtor in property to the extent that such lien…”
In Re Hill, 4 B.R. 310 (Bankr. N.D. Ohio 1980). “This contradicts the language of O.R.C. 2329.661(C). However it will be shown that the Federal bankruptcy statute, 11 U.”
Phillips v. Household Fin. Corp. (In re Phillips), 13 B.R. 811 (Bankr. N.D. Ohio 1981). “Defendants and plaintiffs agreed to submit the matter to the court upon the following agreed facts.”
— Ohio Rev. Code § 2329.661(c) — 1 case
In Re Hill, 4 B.R. 310 (Bankr. N.D. Ohio 1980). “This contradicts the language of O.R.C. 2329.661(C). However it will be shown that the Federal bankruptcy statute, 11 U.”
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