Ohio Revised Code

Ohio Rev. Code § 2735.01 (2026)

Appointment of receiver

✓ current as of May 2026
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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. 2006).
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State Ex Rel. Petro v. Gold, 850 N.E.2d 1218 (Ohio Ct. App. 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 (Ohio Ct. App. 2017). · 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 (Ohio Ct. App. 2017). · 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 (Ohio Ct. App. 2018). · 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. 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 (Ohio Ct. App. 2019). · 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 (Ohio Ct. App. 2014). · 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 (Ohio Ct. App. 2014). · 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 (Ohio Ct. App. 2014). · 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 (Ohio Ct. App. 2022). · 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 (Ohio Ct. App. 2017).
— Ohio Rev. Code § 2735.01(A) — 18 cases
TD Ltd., L.L.C. v. Dudley, 2014 Ohio 3996 (Ohio Ct. App. 2014). “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 (Ohio Ct. App. 2014).
U.S. Bank, N.A. v. Courthouse Crossing Acquisitions, L.L.C., 2017 Ohio 9232 (Ohio Ct. App. 2017). “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. 2008).
Helms v. Thomas, 2018 Ohio 1534 (Ohio Ct. App. 2018). “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 (Ohio Ct. App. 2017). “: {¶ 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 (Ohio Ct. App. 2018). “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 (Ohio Ct. App. 2019).
Jardine v. Jardine, 2022 Ohio 1754 (Ohio Ct. App. 2022).
Rehn v. Invcle150, L.L.C., 2022 Ohio 4634 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 2735.01(A)(2) — 6 cases
U.S. Bank, N.A. v. Courthouse Crossing Acquisitions, L.L.C., 2017 Ohio 9232 (Ohio Ct. App. 2017). “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 (Ohio Ct. App. 2017).
Fannie Mae v. Clarkwood Apts., L.P., 2025 Ohio 5221 (Ohio Ct. App. 2025).
WVJP 2021-4, LP v. Loef, Ltd., 2025 Ohio 463 (Ohio Ct. App. 2025).
Stern v. Rob Oldham Props., L.L.C., 2022 Ohio 2273 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 2735.01(A)(2)(a) — 2 cases
Victor Asset Acquisition, L.L.C. v. Woogerd, 2016 Ohio 1435 (Ohio Ct. App. 2016).
WVJP 2021-4, LP v. Loef, Ltd., 2025 Ohio 463 (Ohio Ct. App. 2025).
— 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 (Ohio Ct. App. 2017). “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 (Ohio Ct. App. 2025).
Rss Wfcm2019-c50 - Oh Wg2, L.L.C. v. Welcome Grp. 2, L.L.C., 2024 Ohio 1613 (Ohio Ct. App. 2024).
WVJP 2021-4, LP v. Loef, Ltd., 2025 Ohio 463 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2735.01(A)(3) — 3 cases
U.S. Bank, N.A. v. Courthouse Crossing Acquisitions, L.L.C., 2017 Ohio 9232 (Ohio Ct. App. 2017). “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 (Ohio Ct. App. 2017).
Victor Asset Acquisition, L.L.C. v. Woogerd, 2016 Ohio 1435 (Ohio Ct. App. 2016).
— Ohio Rev. Code § 2735.01(A)(4) — 8 cases
Morgan v. Jones, 2022 Ohio 1831 (Ohio Ct. App. 2022).
Echols v. Echols, 2022 Ohio 1719 (Ohio Ct. App. 2022). “” 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 (Ohio Ct. App. 2021).
UBS Fin. Servs., Inc. v. Assurance Invest. Mgt., L.L.C., 2019 Ohio 3661 (Ohio Ct. App. 2019).
Smith v. Towslee, 2024 Ohio 5786 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2735.01(A)(5) — 3 cases
Echols v. Echols, 2022 Ohio 1719 (Ohio Ct. App. 2022). “” 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 (Ohio Ct. App. 2019).
Smith v. Towslee, 2024 Ohio 5786 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2735.01(A)(6) — 10 cases
Helms v. Thomas, 2018 Ohio 1534 (Ohio Ct. App. 2018). “91 and R.C. 2735.01 to perform an accounting and to preserve its property during this litigation.”
Young v. Young, 2022 Ohio 2535 (Ohio Ct. App. 2022).
Leight v. Osteosymbionics, L.L.C., 2017 Ohio 5749 (Ohio Ct. App. 2017). “: {¶ 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 (Ohio Ct. App. 2021).
Monroeville v. Gray Matter Advisors, Inc., 2026 Ohio 2110 (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2735.01(A)(7) — 7 cases
Jezerinac v. Dioun, 2020 Ohio 587 (Ohio Ct. App. 2020).
Helms v. Thomas, 2018 Ohio 1534 (Ohio Ct. App. 2018). “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 (Ohio Ct. App. 2021).
Jardine v. Jardine, 2022 Ohio 1754 (Ohio Ct. App. 2022).
Monroeville v. Gray Matter Advisors, Inc., 2026 Ohio 2110 (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2735.01(B) — 12 cases
Metro. Life Ins. v. Triskett Illinois, Inc., 646 N.E.2d 528 (Ohio Ct. App. 1994).
U.S. Bank, N.A. v. 2900 Presidential Drive, L.L.C., 2014 Ohio 1121 (Ohio Ct. App. 2014). “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 (Ohio Ct. App. 2022). “” 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 (Ohio Ct. App. 2014).
Harajli Mgmt. & Inv., Inc. v. A&M Inv. Strategies, Inc., 855 N.E.2d 1262 (Ohio Ct. App. 2006).
— Ohio Rev. Code § 2735.01(C) — 13 cases
State Ex Rel. Petro v. Gold, 850 N.E.2d 1218 (Ohio Ct. App. 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 (Ohio Ct. App. 2011).
State Ex Rel. Skyway Inv. Corp. v. Ashtabula Cnty. Court of Common Pleas, 2011 Ohio 5452 (Ohio 2011).
Sobin v. Lim, 2014 Ohio 4935 (Ohio Ct. App. 2014). “{¶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. 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 (Ohio 2011).
Echols v. Echols, 2022 Ohio 1719 (Ohio Ct. App. 2022). “” 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 Ct. App. 2013).
— Ohio Rev. Code § 2735.01(E) — 10 cases
In re All Cases Against Sager Corp., 2012 Ohio 1444 (Ohio 2012).
Bobb v. Marchant, 469 N.E.2d 847 (Ohio 1984).
Sobin v. Lim, 2014 Ohio 4935 (Ohio Ct. App. 2014). “{¶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. 2010).
— Ohio Rev. Code § 2735.01(F) — 10 cases
State Ex Rel. Petro v. Gold, 850 N.E.2d 1218 (Ohio Ct. App. 2006). “R.C. 2735.01 {¶ 62} The trial court also found that R.”
TD Ltd., L.L.C. v. Dudley, 2014 Ohio 3996 (Ohio Ct. App. 2014). “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 (Ohio Ct. App. 2011).
Sobin v. Lim, 2014 Ohio 4935 (Ohio Ct. App. 2014). “{¶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. 2008).
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