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Ohio Revised Code

Ohio Rev. Code § 2329.92 (2026)

When judgment not enforceable - reciprocity

✓ current as of May 2026
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Effective:
August 29, 1985
Latest Legislation:
Senate Bill 19 - 116th General Assembly
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(A) A foreign country judgment shall not be recognized and enforced pursuant to section 2329.91 of the Revised Code if the judge determines that any of the following are true:

(1) The defendant in the proceedings in the foreign court did not receive notice of the proceedings in sufficient time to enable him to defend;

(2) The foreign country judgment was obtained by fraud;

(3) The claim for relief on which the foreign country judgment is based is repugnant to the public policy of this state;

(4) The foreign country judgment conflicts with another final and conclusive judgment;

(5) The proceedings in the foreign court were contrary to an agreement between the parties under which the dispute in question was to be settled otherwise than by proceedings in that court;

(6) If jurisdiction was based only on personal service, the foreign court was a seriously inconvenient forum for the trial of the action.

(B) A foreign country judgment rendered in a foreign country that does not have a procedure for recognizing judgments made by courts of other countries and their political subdivisions in its statutes, rules, or common law that is substantially similar to sections 2329.90 to 2329.94 of the Revised Code may be recognized and enforced pursuant to section 2329.91 of the Revised Code in the discretion of the court.
Notes of Decisions
Cited in 3 cases, 2014–2020 · leading case: Rossisa Participacoes v. Reynolds & Reynolds Co. (S.D. Ohio 2019).
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State v. Md Helicopters Inc (Ariz. 2020). · cites it 2× “235 § 23A(7); Ohio Rev. Code § 2329.92(B); Tenn. Code Ann.”
Rossisa Participacoes v. Reynolds & Reynolds Co. (S.D. Ohio 2019). · cites it 2× “90(B)), yet the “Decision” does not grant or deny recovery of money; • under Ohio law, a foreign country judgment shall not be recognized and enforced if it is determined that “[t]he claim for relief on which the foreign country judgment is based is repugnant to the public…”
Weir Foulds, L.L.P. v. Restivo, 2014 Ohio 1133 (Ohio Ct. App. 2014). · cites it 3× “91 states, in part: (A) Except as provided in sections 2329.92 and 2329.93 of the Revised Code, any foreign country judgment that is final, conclusive, and enforceable where rendered shall be recognized and enforced by the courts of this state, even though an appeal from the…”
— Ohio Rev. Code § 2329.92(A)(3) — 2 cases
Rossisa Participacoes v. Reynolds & Reynolds Co. (S.D. Ohio 2019). “90(B)), yet the “Decision” does not grant or deny recovery of money; • under Ohio law, a foreign country judgment shall not be recognized and enforced if it is determined that “[t]he claim for relief on which the foreign country judgment is based is repugnant to the public…”
Weir Foulds, L.L.P. v. Restivo, 2014 Ohio 1133 (Ohio Ct. App. 2014). “91 states, in part: (A) Except as provided in sections 2329.92 and 2329.93 of the Revised Code, any foreign country judgment that is final, conclusive, and enforceable where rendered shall be recognized and enforced by the courts of this state, even though an appeal from the…”
— Ohio Rev. Code § 2329.92(B) — 1 case
State v. Md Helicopters Inc (Ariz. 2020). “235 § 23A(7); Ohio Rev. Code § 2329.92(B); Tenn. Code Ann.”
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