Ohio Revised Code

Ohio Rev. Code § 2703.24 (2026)

Proceedings when name of party is unknown

✓ current as of May 2026
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When it appears by affidavit that the name and residence of a necessary party are unknown to the plaintiff, proceedings against him may be had without naming him; and the court shall make an order respecting the publication of notice, but the order shall require not less than six weeks' publication.

Notes of Decisions
Cited in 6 cases (3 in the last 5 years), 1958–2026 · leading case: Gerrity v. Chervenak (Slip Opinion), 2020 Ohio 6705 (Ohio 2020).
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Gerrity v. Chervenak (Slip Opinion), 2020 Ohio 6705 (Ohio 2020). · cites it 12× “4(A)(1) and R.C. 2703.24 and urges this court to import the requirements of those provisions into the Dormant Mineral Act.”
Patrick v. Ellman, 2020 Ohio 3312 (Ohio Ct. App. 2020). · cites it 10× “, Wanda's "unknown heirs," to be parties to the litigation pursuant to R.C. 2703.24. By its terms, R.C. 2703.24 recognizes the "party" status of persons whose names and residences are unknown and are served with the summons and complaint by publication.”
Reid v. Williams, 2024 Ohio 3332 (Ohio Ct. App. 2024). · cites it 8× “For the reasons that follow, we will reverse the judgment of the probate court in part and remand the matter for the probate court to enter a default judgment against the unknown heirs of Randall Ed Lucas. In all other respects, the judgment of the probate court will be affirmed.”
Moore v. SWN Prod. Co., L.L.C., 2024 Ohio 5517 (Ohio Ct. App. 2024). “4 and R.C. 2703.24. Id. at ¶ 27. The General Assembly did not intend service by certified mail under R.”
Lamancusa v. Webb, 2026 Ohio 229 (Ohio Ct. App. 2026). “211 , 214 (1958) (R.C. 2703.24 authorizes “the usual procedure of obtaining service by publication on the decedent’s ‘unknown heirs’”).”
Fletcher v. First Nat'l Bank, 167 Ohio St. (N.S.) 211 (Ohio 1958). · cites it 2× “For some reason the contestants had not employed the usual procedure of obtaining service by publication on the decedent’s “unknown heirs,” as authorized by the provisions of Section 2703.24, Revised Code. In the opinion in the Gravier case appears the following concluding…”
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