Ohio Rev. Code » Chapter 2735
Ohio Revised Code

Ohio Rev. Code § 2735.01 (2026)

Appointment of receiver

✓ laws through the 2026 session (checked Sept. 2026)
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Effective:
March 23, 2015
Latest Legislation:
House Bill 9 - 130th General Assembly
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(A) A receiver may be appointed by the supreme court or a judge thereof, the court of appeals or a judge thereof in the judge's district, the court of common pleas or a judge thereof in the judge's county, or the probate court, in causes pending in such courts respectively, in the following cases:

(1) In an action by a vendor to vacate a fraudulent purchase of property, or by a creditor to subject property or a fund to the creditor's claim, or between partners or others jointly owning or interested in any property or fund, on the application of the plaintiff, or of a party whose right to or interest in the property or fund, or the proceeds of the property or fund, is probable, and when it is shown that the property or fund is in danger of being lost, removed, or materially injured;

(2) In an action by a mortgagee, for the foreclosure of the mortgagee's mortgage and sale of the mortgaged property, when it appears that the mortgaged property is in danger of being lost, removed, materially injured, diminished in value, or squandered, or that the condition of the mortgage has not been performed, and either of the following applies:

(a) The property is probably insufficient to discharge the mortgage debt.

(b) The mortgagor has consented in writing to the appointment of a receiver.

(3) To enforce a contractual assignment of rents and leases;

(4) After judgment, to carry the judgment into effect;

(5) After judgment, to dispose of the property according to the judgment, or to preserve it during the pendency of an appeal, or when an execution has been returned unsatisfied and the judgment debtor refuses to apply the property in satisfaction of the judgment;

(6) When a corporation, limited liability company, partnership, limited partnership, or other entity has been dissolved, is insolvent, is in imminent danger of insolvency, or has forfeited its corporate, limited liability company, partnership, limited partnership, or other entity rights;

(7) In all other cases in which receivers have been appointed by the usages of equity.

(B) A receiver appointed under division (A)(1), (2), (3), or (5) of this section shall be appointed only with respect to the particular property that is the subject of the action in which the appointment of a receiver is sought.

(C) A receiver appointed under division (A)(6) of this section may be appointed to manage all the affairs of the corporation, limited liability company, partnership, limited partnership, or other entity with respect to which the appointment of a receiver is sought.

(D) A receiver appointed under division (A)(4) or (7) of this section may be appointed to manage all the affairs of the corporation, limited liability company, partnership, limited partnership, or other entity, or only with respect to particular property as determined by the court.
Notes of Decisions
Cited in 112 cases (24 in the last 5 years), 1965–2026 · leading case: State ex rel. Petro v. Gold, 850 N.E.2d 1218 (Ohio Ct. App. 10th Dist. 2006).
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State ex rel. Petro v. Gold, 850 N.E.2d 1218 (Ohio Ct. App. 10th Dist. 2006). · cites it 10× “R.C. 2735.01 {¶ 62} The trial court also found that R.”
U.S. Bank, N.A. v. Courthouse Crossing Acquisitions, L.L.C., 2017-Ohio-9232, 103 N.E.3d 300. · cites it 8× “R.C. 2735.01 governs the appointment of receivers and relevantly provides that a receiver may be appointed in these cases: (2) In an action by a mortgagee, for the foreclosure of the mortgagee's mortgage and sale of the mortgaged property, when it appears that the mortgaged…”
Leight v. Osteosymbionics, L.L.C., 2017-Ohio-5749, 94 N.E.3d 995. · cites it 12× “: {¶ 1} The central question we are called upon to answer is whether, under R.C. 2735.01, a trial court may grant an ex parte emergency motion to appoint a receiver to manage and operate an Ohio limited liability company.”
State ex rel. Celebrezze v. Gibbs, 573 N.E.2d 62 (Ohio 1991). · cites it 3× “R.C. 2735.01 governs the appointment of receivers, and provides in pertinent part: “A receiver may be appointed by * * * the court of common pleas or a judge thereof * * * in causes pending in such courts respectively, in the following cases: a* * * “(C) After judgment, to carry…”
Helms v. Thomas, 2018-Ohio-1534, 111 N.E.3d 72. · cites it 13× “91 and R.C. 2735.01 to perform an accounting and to preserve its property during this litigation.”
Castlebrook, Ltd. v. Dayton Props. Ltd. P'ship, 604 N.E.2d 808 (Ohio Ct. App. 2d Dist. 1992). · cites it 3× “R.C. 2735.01 provides that a receiver may be appointed in a mortgage foreclosure action: “A receiver may be appointed by * * * the court of common pleas or a judge thereof * * * in the following cases: (( * * * “(B) In an action by a mortgagee, for the foreclosure of his…”
State ex rel. Yost v. Summer Rays, Inc., 2019-Ohio-3907. · cites it 5× “{¶ 12} R.C. 2735.01 provides for the appointment of a receiver by a common pleas court in specified circumstances.”
U.S. Bank, N.A. v. 2900 Presidential Drive, L.L.C., 2014-Ohio-1121. · cites it 6× “01, which governs the appointment of receivers, provides that a receiver may be appointed by the court of common pleas or a judge thereof in his or her county, in the following cases: (B) In an action by a mortgagee, for the foreclosure of his mortgage and sale of the mortgaged…”
TD Ltd., L.L.C. v. Dudley, 2014-Ohio-3996. · cites it 11× “1: {¶ 18} MOVANT BATH STATE BANK HAS NOT PROVEN BY CLEAR AND CONVINCING EVIDENCE THAT IT IS ENTITLED TO APPOINTMENT OF A RECEIVER UNDER O.R.C. §2735.01. {¶ 19} Assignment of Error No.”
Whittiker v. Deutsche Bank Nat'l Trust Co., 605 F. Supp. 2d 914 (N.D. Ohio 2009). · cites it 2× “Count 2 of the Complaint alleges that the defendants violated Ohio's RICO laws, Ohio Rev.”
Sobin v. Lim, 2014-Ohio-4935, 21 N.E.3d 344. · cites it 8× “{¶15} R.C. 2735.01 sets forth the situations in which appointment of a receiver is warranted: A receiver may be appointed by the supreme court or a judge thereof, the court of appeals or a judge thereof in his district, the court of common pleas or a judge thereof in his county,…”
Echols v. Echols, 2022-Ohio-1719, 190 N.E.3d 698. · cites it 4× “” R.C. 2735.01(A)(4). “A receiver appointed under division (A)(4) * * * may be appointed to manage all the affairs * * * with respect to particular property as determined by the court.”
Show all 112 citing cases →
Ohio Rev. Code § 2735.01(4): 1 case
Clarkwestern Dietrich Bldg. Sys., L.L.C. v. Certified Steel Stud Assn., 2017-Ohio-8129, 98 N.E.3d 860.
Ohio Rev. Code § 2735.01(A): 18 cases
TD Ltd., L.L.C. v. Dudley, 2014-Ohio-3996. “1: {¶ 18} MOVANT BATH STATE BANK HAS NOT PROVEN BY CLEAR AND CONVINCING EVIDENCE THAT IT IS ENTITLED TO APPOINTMENT OF A RECEIVER UNDER O.R.C. §2735.01. {¶ 19} Assignment of Error No.”
Harold Pollock Co., L.P.A. v. Bishop, 2014-Ohio-1132.
U.S. Bank, N.A. v. Courthouse Crossing Acquisitions, L.L.C., 2017-Ohio-9232, 103 N.E.3d 300. “R.C. 2735.01 governs the appointment of receivers and relevantly provides that a receiver may be appointed in these cases: (2) In an action by a mortgagee, for the foreclosure of the mortgagee's mortgage and sale of the mortgaged property, when it appears that the mortgaged…”
Cunningham v. Ohio Police & Fire Pension Fund, 888 N.E.2d 453 (Ohio Ct. App. 8th Dist. 2008).
Helms v. Thomas, 2018-Ohio-1534, 111 N.E.3d 72. “91 and R.C. 2735.01 to perform an accounting and to preserve its property during this litigation.”
Ohio Rev. Code § 2735.01(A)(1): 10 cases
Leight v. Osteosymbionics, L.L.C., 2017-Ohio-5749, 94 N.E.3d 995. “: {¶ 1} The central question we are called upon to answer is whether, under R.C. 2735.01, a trial court may grant an ex parte emergency motion to appoint a receiver to manage and operate an Ohio limited liability company.”
Helms v. Thomas, 2018-Ohio-1534, 111 N.E.3d 72. “91 and R.C. 2735.01 to perform an accounting and to preserve its property during this litigation.”
Ralls v. 2222 Internatl., L.L.C., 2019-Ohio-4261.
Jardine v. Jardine, 2022-Ohio-1754.
Rehn v. Invcle150, L.L.C., 2022-Ohio-4634.
Ohio Rev. Code § 2735.01(A)(2): 6 cases
U.S. Bank, N.A. v. Courthouse Crossing Acquisitions, L.L.C., 2017-Ohio-9232, 103 N.E.3d 300. “R.C. 2735.01 governs the appointment of receivers and relevantly provides that a receiver may be appointed in these cases: (2) In an action by a mortgagee, for the foreclosure of the mortgagee's mortgage and sale of the mortgaged property, when it appears that the mortgaged…”
City of Cincinnati v. PE Alms Hill Realty, LLC, 2017-Ohio-1569, 90 N.E.3d 156.
Fannie Mae v. Clarkwood Apts., L.P., 2025-Ohio-5221.
WVJP 2021-4, LP v. Loef, Ltd., 2025-Ohio-463.
Stern v. Rob Oldham Props., L.L.C., 2022-Ohio-2273.
Ohio Rev. Code § 2735.01(A)(2)(a): 2 cases
Victor Asset Acquisition, L.L.C. v. Woogerd, 2016-Ohio-1435.
WVJP 2021-4, LP v. Loef, Ltd., 2025-Ohio-463.
Ohio Rev. Code § 2735.01(A)(2)(b): 4 cases
U.S. Bank, N.A. v. Courthouse Crossing Acquisitions, L.L.C., 2017-Ohio-9232, 103 N.E.3d 300. “R.C. 2735.01 governs the appointment of receivers and relevantly provides that a receiver may be appointed in these cases: (2) In an action by a mortgagee, for the foreclosure of the mortgagee's mortgage and sale of the mortgaged property, when it appears that the mortgaged…”
Fannie Mae v. Clarkwood Apts., L.P., 2025-Ohio-5221.
RSS Wfcm2019-c50 - Oh Wg2, L.L.C. v. Welcome Grp. 2, L.L.C., 2024-Ohio-1613.
WVJP 2021-4, LP v. Loef, Ltd., 2025-Ohio-463.
Ohio Rev. Code § 2735.01(A)(3): 3 cases
U.S. Bank, N.A. v. Courthouse Crossing Acquisitions, L.L.C., 2017-Ohio-9232, 103 N.E.3d 300. “R.C. 2735.01 governs the appointment of receivers and relevantly provides that a receiver may be appointed in these cases: (2) In an action by a mortgagee, for the foreclosure of the mortgagee's mortgage and sale of the mortgaged property, when it appears that the mortgaged…”
City of Cincinnati v. PE Alms Hill Realty, LLC, 2017-Ohio-1569, 90 N.E.3d 156.
Victor Asset Acquisition, L.L.C. v. Woogerd, 2016-Ohio-1435.
Ohio Rev. Code § 2735.01(A)(4): 8 cases
Morgan v. Jones, 2022-Ohio-1831.
Echols v. Echols, 2022-Ohio-1719, 190 N.E.3d 698. “” R.C. 2735.01(A)(4). “A receiver appointed under division (A)(4) * * * may be appointed to manage all the affairs * * * with respect to particular property as determined by the court.”
Harbor Island Assn., Inc. v. Stecks Buckeye Storage Units, L.L.C., 2021-Ohio-2969.
UBS Fin. Servs., Inc. v. Assurance Invest. Mgt., L.L.C., 2019-Ohio-3661.
Smith v. Towslee, 2024-Ohio-5786.
Ohio Rev. Code § 2735.01(A)(5): 3 cases
Echols v. Echols, 2022-Ohio-1719, 190 N.E.3d 698. “” R.C. 2735.01(A)(4). “A receiver appointed under division (A)(4) * * * may be appointed to manage all the affairs * * * with respect to particular property as determined by the court.”
UBS Fin. Servs., Inc. v. Assurance Invest. Mgt., L.L.C., 2019-Ohio-3661.
Smith v. Towslee, 2024-Ohio-5786.
Ohio Rev. Code § 2735.01(A)(6): 10 cases
Helms v. Thomas, 2018-Ohio-1534, 111 N.E.3d 72. “91 and R.C. 2735.01 to perform an accounting and to preserve its property during this litigation.”
Young v. Young, 2022-Ohio-2535.
Leight v. Osteosymbionics, L.L.C., 2017-Ohio-5749, 94 N.E.3d 995. “: {¶ 1} The central question we are called upon to answer is whether, under R.C. 2735.01, a trial court may grant an ex parte emergency motion to appoint a receiver to manage and operate an Ohio limited liability company.”
Cuyahoga Cty. Case Mgt. v. Clark Indus. Insulation Co., 2021-Ohio-1405, 172 N.E.3d 448.
Monroeville v. Gray Matter Advisors, Inc., 2026-Ohio-2110.
Ohio Rev. Code § 2735.01(A)(7): 7 cases
Jezerinac v. Dioun, 2020-Ohio-587, 152 N.E.3d 430.
Helms v. Thomas, 2018-Ohio-1534, 111 N.E.3d 72. “91 and R.C. 2735.01 to perform an accounting and to preserve its property during this litigation.”
Cuyahoga Cty. Case Mgt. v. Clark Indus. Insulation Co., 2021-Ohio-1405, 172 N.E.3d 448.
Jardine v. Jardine, 2022-Ohio-1754.
Monroeville v. Gray Matter Advisors, Inc., 2026-Ohio-2110.
Ohio Rev. Code § 2735.01(B): 12 cases
Metro. Life Ins. v. Triskett Illinois, Inc., 646 N.E.2d 528 (Ohio Ct. App. 1st Dist. 1994).
U.S. Bank, N.A. v. 2900 Presidential Drive, L.L.C., 2014-Ohio-1121. “01, which governs the appointment of receivers, provides that a receiver may be appointed by the court of common pleas or a judge thereof in his or her county, in the following cases: (B) In an action by a mortgagee, for the foreclosure of his mortgage and sale of the mortgaged…”
Echols v. Echols, 2022-Ohio-1719, 190 N.E.3d 698. “” R.C. 2735.01(A)(4). “A receiver appointed under division (A)(4) * * * may be appointed to manage all the affairs * * * with respect to particular property as determined by the court.”
Wells Fargo Bank, N.A. v. Odita, 2014-Ohio-2540.
Harajli Mgmt. & Inv., Inc. v. A&M Inv. Strategies, Inc., 855 N.E.2d 1262 (Ohio Ct. App. 6th Dist. 2006).
Ohio Rev. Code § 2735.01(C): 13 cases
State ex rel. Petro v. Gold, 850 N.E.2d 1218 (Ohio Ct. App. 10th Dist. 2006). “R.C. 2735.01 {¶ 62} The trial court also found that R.”
Vikoz Ent., L.L.C. v. Wizards of Plastic Recycling, Inc., 2011-Ohio-4486.
State ex rel. Skyway Inv. Corp. v. Ashtabula Cnty. Court of Common Pleas, 2011-Ohio-5452, 130 Ohio St. 3d 220.
Sobin v. Lim, 2014-Ohio-4935, 21 N.E.3d 344. “{¶15} R.C. 2735.01 sets forth the situations in which appointment of a receiver is warranted: A receiver may be appointed by the supreme court or a judge thereof, the court of appeals or a judge thereof in his district, the court of common pleas or a judge thereof in his county,…”
Cunningham v. Ohio Police & Fire Pension Fund, 888 N.E.2d 453 (Ohio Ct. App. 8th Dist. 2008).
Ohio Rev. Code § 2735.01(D): 3 cases
State ex rel. Skyway Inv. Corp. v. Ashtabula Cnty. Court of Common Pleas, 2011-Ohio-5452, 130 Ohio St. 3d 220.
Echols v. Echols, 2022-Ohio-1719, 190 N.E.3d 698. “” R.C. 2735.01(A)(4). “A receiver appointed under division (A)(4) * * * may be appointed to manage all the affairs * * * with respect to particular property as determined by the court.”
2115-2121 Ontario Bldg., L.L.C. v. Anter, 2013-Ohio-2995.
Ohio Rev. Code § 2735.01(E): 10 cases
In re All Cases Against Sager Corp., 2012-Ohio-1444, 132 Ohio St. 3d 5.
Bobb v. Marchant, 469 N.E.2d 847 (Ohio 1984).
Sobin v. Lim, 2014-Ohio-4935, 21 N.E.3d 344. “{¶15} R.C. 2735.01 sets forth the situations in which appointment of a receiver is warranted: A receiver may be appointed by the supreme court or a judge thereof, the court of appeals or a judge thereof in his district, the court of common pleas or a judge thereof in his county,…”
Vought Indus., Inc. v. Tracy, 648 N.E.2d 1364 (Ohio 1995).
In re All Cases Against Sager Corp., 936 N.E.2d 1034 (Ohio Ct. App. 8th Dist. 2010).
Ohio Rev. Code § 2735.01(F): 10 cases
State ex rel. Petro v. Gold, 850 N.E.2d 1218 (Ohio Ct. App. 10th Dist. 2006). “R.C. 2735.01 {¶ 62} The trial court also found that R.”
TD Ltd., L.L.C. v. Dudley, 2014-Ohio-3996. “1: {¶ 18} MOVANT BATH STATE BANK HAS NOT PROVEN BY CLEAR AND CONVINCING EVIDENCE THAT IT IS ENTITLED TO APPOINTMENT OF A RECEIVER UNDER O.R.C. §2735.01. {¶ 19} Assignment of Error No.”
Huntington Natl. Bank v. Prospect Park, L.L.C., 2011-Ohio-5391.
Sobin v. Lim, 2014-Ohio-4935, 21 N.E.3d 344. “{¶15} R.C. 2735.01 sets forth the situations in which appointment of a receiver is warranted: A receiver may be appointed by the supreme court or a judge thereof, the court of appeals or a judge thereof in his district, the court of common pleas or a judge thereof in his county,…”
Lockard v. Lockard, 886 N.E.2d 276 (Ohio Ct. App. 4th Dist. 2008).
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