Ohio Rev. Code » Chapter 2703
Ohio Revised Code

Ohio Rev. Code § 2703.14 (2026)

Service by publication

✓ current as of May 2026
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Effective:
June 23, 1994
Latest Legislation:
House Bill 208 - 120th General Assembly
PDF:
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Service may be made by publication in any of the following cases:

(A) In an action for the recovery of real property or of an estate or interest in real property, when the defendant is not a resident of this state or his place of residence cannot be ascertained;

(B) In an action for the partition of real property, when the defendant is not a resident of this state or his place of residence cannot be ascertained;

(C) In an action to foreclose a mortgage or to enforce a lien or other encumbrance or charge on real property, when the defendant is not a resident of this state or his place of residence cannot be ascertained;

(D) In an action to compel the specific performance of a contract for the sale of real property, when the defendant is not a resident of this state or his place of residence cannot be ascertained;

(E) In connection with giving notice of the admission of a will to probate, when the place of residence of a defendant or other person entitled to notice is not known and cannot with reasonable diligence be ascertained;

(F) In an action by an executor, administrator, guardian, or trustee seeking the direction of the court respecting the trust or property to be administered and the rights of the parties in interest, when the defendant is not a resident of this state or his place of residence cannot be ascertained;

(G) In an action in which it is sought by a provisional remedy to take or to appropriate in any way property of the defendant, when the defendant is not a resident of this state or is a foreign corporation or his place of residence cannot be ascertained;

(H) In an action against a corporation organized under the laws of this state that has failed to elect officers or to appoint an agent upon whom service of summons can be made and that has no place of doing business in this state;

(I) In an action that relates to or the subject of which is real or personal property in this state, when the defendant has or claims a lien on the property or an actual or contingent interest in the property or the relief demanded consists wholly or partly in excluding him from any interest in the property, and the defendant is not a resident of this state or is a foreign corporation or his place of residence cannot be ascertained;

(J) In an action against an executor, administrator, or guardian who has given bond in that capacity in this state but who, at the time of the commencement of the action, is not a resident of this state or his place of residence cannot be ascertained;

(K) In an action or proceeding for a new trial or other relief after judgment, or to impeach a judgment or order for fraud, or to obtain an order of satisfaction thereof, when the defendant is not a resident of this state or his place of residence cannot be ascertained;

(L) In an action in which the defendant, being a resident of this state, has departed from the county of his residence with intent to delay or defraud his creditors or to avoid the service of a summons, or keeps himself concealed with a similar intent.
Notes of Decisions
Cited in 33 cases (12 in the last 5 years), 1954–2026 · leading case: Sizemore v. Smith, 453 N.E.2d 632 (Ohio 1983).
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Sizemore v. Smith, 453 N.E.2d 632 (Ohio 1983). · cites it 4× “4 (A) and R.C. 2703.14 (L). Resolution of this issue depends upon the answers to two questions: first, whether appellee exercised reasonable diligence in attempting to locate appellant and second, whether appellant kept himself concealed with the intent to avoid service of…”
Brooks v. Rollins, 457 N.E.2d 1158 (Ohio 1984). · cites it 8× “” R.C. 2703.14 sets forth those categories of cases where service by publication is authorized by law.”
Palazzi v. Est. of Gardner, 512 N.E.2d 971 (Ohio 1987). · cites it 3× “” 1 Further, R.C. 2703.14(E) permits the utilization of constructive notice with respect to certain individuals and entities.”
Khatib v. Peters, 2015 Ohio 5144 (Ohio Ct. App. 2015). · cites it 6× “) {¶16} R.C. 2703.14 sets forth those categories of cases where service by publication is authorized by law.”
Fernwalt v. Our Lady of Kilgore, 2017 Ohio 1260 (Ohio Ct. App. 2017). · cites it 4× “4 and R.C. 2703.14. The notice -4- indicated the last day to answer the complaint was April 17, 2014 and that bench trial was set for May 19, 2014.”
Helms v. Nationwide Ins. Co. of Am., 280 F.R.D. 354 (S.D. Ohio 2012). · cites it 5× “4, O.R.C. § 2703.14 sets forth the limited types of cases in which service by publication can be made.”
Maryhew v. Yova, 464 N.E.2d 538 (Ohio 1984). “4 and the provisions of the Ohio Revised Code, such as R.C. 2703.14. It is a fundamental principle that no judgment can be entered against a party when the court has not obtained in personam jurisdiction over that party.”
Franks v. Reynolds, 2021 Ohio 3247 (Ohio Ct. App. 2021). · cites it 5× “{¶4} The complaint stated the four defendants at issue could not be located with reasonable diligence and service by publication was appropriate under R.C. 2703.14 and Civ.R. 4.4(A). Appellees thereafter filed an affidavit for publication stating the addresses for the four…”
Third Fed. S. & L. Assn. v. Taylor, 2017 Ohio 7620 (Ohio Ct. App. 2017). “For the sake of completeness, we note that Third Federal was authorized to resort to service by publication by R.C. 2703.14(C), which permits such service "[i]n an action to foreclose a mortgage or to enforce a lien or other encumbrance or charge on real property, when * * *…”
Corrao v. Bennett, 2020 Ohio 2822 (Ohio Ct. App. 2020). “Relevant to this case, R.C. 2703.14(L) states that service by publication is authorized by law in the following case: In an action where the defendant, being a resident of this state, has departed from the county of his residence with intent to delay or defraud his creditors or…”
Knapp v. Husa, 2020 Ohio 6986 (Ohio Ct. App. 2020). “4 and R.C. 2703.14 are applicable to this case,” and, if so, follow the proper procedure to effectuate service by publication.”
Kraus v. Maurer, 740 N.E.2d 722 (Ohio Ct. App. 2000). “2d 632 ; R.C. 2703.14; Civ.R. 4.4(A). Reasonable diligence requires taking steps that an individual of ordinary prudence would reasonably expect to be successful in locating a defendant’s address and requires counsel to use common and readily available sources in the search,…”
Show all 33 citing cases →
— Ohio Rev. Code § 2703.14(A) — 3 cases
Franks v. Reynolds, 2021 Ohio 3247 (Ohio Ct. App. 2021). “{¶4} The complaint stated the four defendants at issue could not be located with reasonable diligence and service by publication was appropriate under R.C. 2703.14 and Civ.R. 4.4(A). Appellees thereafter filed an affidavit for publication stating the addresses for the four…”
Mammone v. Reynolds, 2021 Ohio 3248 (Ohio Ct. App. 2021).
McManus v. Anderson, 2025 Ohio 2542 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2703.14(C) — 1 case
Third Fed. S. & L. Assn. v. Taylor, 2017 Ohio 7620 (Ohio Ct. App. 2017). “For the sake of completeness, we note that Third Federal was authorized to resort to service by publication by R.C. 2703.14(C), which permits such service "[i]n an action to foreclose a mortgage or to enforce a lien or other encumbrance or charge on real property, when * * *…”
— Ohio Rev. Code § 2703.14(E) — 1 case
Palazzi v. Est. of Gardner, 512 N.E.2d 971 (Ohio 1987). “” 1 Further, R.C. 2703.14(E) permits the utilization of constructive notice with respect to certain individuals and entities.”
— Ohio Rev. Code § 2703.14(F) — 1 case
Jeffco Resources, Inc. v. Abrecht, 2023 Ohio 4712 (Ohio Ct. App. 2023).
— Ohio Rev. Code § 2703.14(H) — 1 case
Urdiales v. Latin Am. Club of Defiance, Ohio, 2026 Ohio 1239 (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2703.14(L) — 8 cases
Brooks v. Rollins, 457 N.E.2d 1158 (Ohio 1984). “” R.C. 2703.14 sets forth those categories of cases where service by publication is authorized by law.”
Khatib v. Peters, 2015 Ohio 5144 (Ohio Ct. App. 2015). “) {¶16} R.C. 2703.14 sets forth those categories of cases where service by publication is authorized by law.”
Helms v. Nationwide Ins. Co. of Am., 280 F.R.D. 354 (S.D. Ohio 2012). “4, O.R.C. § 2703.14 sets forth the limited types of cases in which service by publication can be made.”
Corrao v. Bennett, 2020 Ohio 2822 (Ohio Ct. App. 2020). “Relevant to this case, R.C. 2703.14(L) states that service by publication is authorized by law in the following case: In an action where the defendant, being a resident of this state, has departed from the county of his residence with intent to delay or defraud his creditors or…”
Ohio Fair Plan Underwriting Assn. v. Goldstein, 441 N.E.2d 1146 (Ohio Ct. App. 1982).
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