Ohio Revised Code

Ohio Rev. Code § 2703.26 (2026)

Lis pendens in general

✓ current as of May 2026
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When a complaint is filed, the action is pending so as to charge a third person with notice of its pendency. While pending, no interest can be acquired by third persons in the subject of the action, as against the plaintiff's title.

Notes of Decisions
Cited in 66 cases (13 in the last 5 years), 1960–2025 · leading case: ABN AMRO Mortg. Grp., Inc. v. Jackson, 824 N.E.2d 600 (Ohio Ct. App. 2005).
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ABN AMRO Mortg. Grp., Inc. v. Jackson, 824 N.E.2d 600 (Ohio Ct. App. 2005). · cites it 9× “{¶ 17} The doctrine of lis pendens, codified in R.C. 2703.26, states: “When summons has been served or publication made, the action is pending so as to charge third persons with notice of its pendency.”
Beneficial Ohio, Inc. v. Ellis, 902 N.E.2d 452 (Ohio 2009). · cites it 13× “{¶ 1} The question before us in this case is whether service upon one defendant in a multidefendant lawsuit is sufficient to consider the action “pending” for purposes of the doctrine of lis pendens, as codified in former R.C. 2703.26. We hold that pursuant to former R.”
Huntington Natl. Bank v. R Kids Count Learning Ctr., L.L.C., 2017 Ohio 7837 (Ohio Ct. App. 2017). · cites it 6× “" R.C. 2703.26. Here, paradoxically, while the trial court applied lis pendens to preserve Huntington's right to foreclose on the matter, the court declined to apply lis pendens to preclude termination of the lease itself.”
Sorrell v. Micomonaco, 2017 Ohio 1498 (Ohio Ct. App. 2017). · cites it 6× “Lis Pendens, Generally {¶ 50} R.C. 2703.26 provides: When a complaint is filed, the action is pending so as to charge a third persons with notice of its pendency.”
Hunter v. Bank of New York (In Re Anderson), 266 B.R. 128 (Bankr. N.D. Ohio 2001). · cites it 6× “O.R.C. § 2703.26. 1 The effect of the doctrine is that any party acquiring an interest in an item of property while a suit is pending, takes that property subject to the final outcome of the suit.”
Rhiel v. Cent. Mortg. Co. (In Re Kebe), 469 B.R. 778 (Bankr. S.D. Ohio 2012). · cites it 6× “While pending, no interest can be acquired by third persons in the subject of the action, as against the plaintiffs title.”
Bates Recycling, Inc. v. Conaway, 2018 Ohio 5056 (Ohio Ct. App. 2018). · cites it 2× “3 R.C. 2703.26 codified the doctrine of lis pendens and reads as follows: When a complaint is filed, the action is pending so as to charge a third person with notice of its pendency.”
Irwin Mortg. Corp. v. DuPee, 966 N.E.2d 315 (Ohio Ct. App. 2012). · cites it 4× “The doctrine was codified in Ohio in R.C. 2703.26. Bank of New York v. Barclay, 10th Dist.”
Bates v. Postulate Investments, L.L.C., 892 N.E.2d 937 (Ohio Ct. App. 2008). · cites it 2× “Doctrine of Lis Pendens {¶ 14} The doctrine of lis pendens is found in R.C. 2703.26 and states as follows: {¶ 15} “When summons has been served or publication made, the [foreclosure] action is pending so as to charge third persons with notice of its pendency.”
Ransier v. Stand. Fed. Bank, FSG (In Re Collins), 292 B.R. 842 (Bankr. S.D. Ohio 2003). · cites it 2× “2 Ohio Revised Code § 2703.26. Even though the facts are different between Periandri and this case, the Court concludes that the foreclosure suit by Standard Federal provided constructive notice to the world of, at the very least, its equitable interest in the property.”
Katz v. Banning, 617 N.E.2d 729 (Ohio Ct. App. 1992). · cites it 2× “The common-law doctrine of lis pendens is codified in R.C. 2703.26, which reads: “When summons has been served or publication made, the action is pending so as to charge third persons with notice of its pendency.”
Levin v. George Fraam & Sons, Inc., 585 N.E.2d 527 (Ohio Ct. App. 1990). · cites it 3× “The common law doctrine of lis pendens has been codified in R.C. 2703.26 which reads: "When summons has been served or publication made, the action is pending so as to charge third persons with notice of its pendency.”
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