Ohio Revised Code

Ohio Rev. Code § 2901.04 (2026)

Rules of construction for statutes and rules of procedure

✓ current as of May 2026
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(A) Except as otherwise provided in division (C) or (D) of this section, sections of the Revised Code defining offenses or penalties shall be strictly construed against the state, and liberally construed in favor of the accused.

(B) Rules of criminal procedure and sections of the Revised Code providing for criminal procedure shall be construed so as to effect the fair, impartial, speedy, and sure administration of justice.

(C) Any provision of a section of the Revised Code that refers to a previous conviction of or plea of guilty to a violation of a section of the Revised Code or of a division of a section of the Revised Code shall be construed to also refer to a previous conviction of or plea of guilty to a substantially equivalent offense under an existing or former law of this state, another state, or the United States or under an existing or former municipal ordinance.

(D) Any provision of the Revised Code that refers to a section, or to a division of a section, of the Revised Code that defines or specifies a criminal offense shall be construed to also refer to an existing or former law of this state, another state, or the United States, to an existing or former municipal ordinance, or to an existing or former division of any such existing or former law or ordinance that defines or specifies, or that defined or specified, a substantially equivalent offense.

Notes of Decisions
Cited in 361 cases (38 in the last 5 years), 1954–2026 · leading case: State v. Chappell, 2010 Ohio 5991 (Ohio 2010).
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State v. Chappell, 2010 Ohio 5991 (Ohio 2010). · cites it 34× “146, 150 Ohio Laws, Part V, 7787-7788 (modifying division (A) of R.C. 2901.04 by adding the phrase “or (D)” to the phrase “Except as otherwise provided in division (C) of this section” and enacting new division (D)).”
State v. Gonzales (Slip Opinion), 2017 Ohio 777 (Ohio 2017). · cites it 6× “An offender who possesses five grams of cocaine should receive the same penalty as the offender who has five grams of cocaine and ten grams of filler material.”
State v. White, 2012 Ohio 2583 (Ohio 2012). · cites it 8× “Even if there were an ambiguity, meaning two reasonable ways of reading the statute, R.C. 2901.04 provides that we must read the language of the relevant statute not in favor of the government, but in favor of the accused.”
State v. Joseph, 2010 Ohio 954 (Ohio 2010). · cites it 4× “{¶ 30} Furthermore, R.C. 2901.04(A) requires that statutes defining offenses or penalties be strictly construed against the state and liberally in favor of the defendant.”
State v. Pribble (Slip Opinion), 2019 Ohio 4808 (Ohio 2019). · cites it 14× “14(A)(3)(b) are in conflict, and applying the rule of lenity—codified in R.C. 2901.04(A) (“sections of the Revised Code defining offenses or penalties shall be strictly construed against the state, and liberally construed in favor of the accused”)—determined that R.”
State v. Sowell (Slip Opinion), 2016 Ohio 8025 (Ohio 2016). · cites it 3× “” See also R.C. 2901.04(B). {¶ 98} We conclude that the term “signed,” as used in Crim.”
State v. Osie (Slip Opinion), 2014 Ohio 2966 (Ohio 2014). · cites it 4× “” Because the term “criminal action or proceeding” was undefined in the statute, we interpreted the term to mean “a formal process involving a court.”
Zant v. Stephens, 462 U.S. 862 (1983). · cites it 2× “If, as Duling establishes, the Constitution prohibits a State from defining a crime (such as murder of a police officer) and then leaving the decision whether to impose the death sentence to the unchecked discretion of the jury, it must also prohibit a State from defining a…”
State v. Whitfield, 2010 Ohio 2 (Ohio 2010). · cites it 2× “The trial court determined that a plea of guilty was sufficient to satisfy the prior-conviction element. The court of appeals reversed, holding that a judgment entry of conviction was necessary to constitute a “conviction.”
State v. Stevens, 2014 Ohio 1932 (Ohio 2014). · cites it 8× “{¶ 12} We are guided by the rules of statutory interpretation as codified in the rule of lenity, R.C. 2901.04(A). There, the legislature has made it clear that “sections of the Revised Code defining offenses or penalties shall be strictly construed against the state, and…”
State v. Roberts (Slip Opinion), 2017 Ohio 2998 (Ohio 2017). · cites it 3× “{¶ 41} Roberts contends that we should take “guidance” from R.C. 2901.04(A), the rule of lenity. But the rule of lenity is not relevant here.”
State v. Harp, 2016 Ohio 4921 (Ohio Ct. App. 2016). · cites it 2× “041(C)(1) was to "impose the maximum mandatory sentence statutorily allowable on those such offenders when the offenses was a felony of the third degree[.”
Show all 361 citing cases →
— Ohio Rev. Code § 2901.04(A) — 279 cases
State v. Chappell, 2010 Ohio 5991 (Ohio 2010). “146, 150 Ohio Laws, Part V, 7787-7788 (modifying division (A) of R.C. 2901.04 by adding the phrase “or (D)” to the phrase “Except as otherwise provided in division (C) of this section” and enacting new division (D)).”
State v. Gonzales (Slip Opinion), 2017 Ohio 777 (Ohio 2017). “An offender who possesses five grams of cocaine should receive the same penalty as the offender who has five grams of cocaine and ten grams of filler material.”
State v. Pribble (Slip Opinion), 2019 Ohio 4808 (Ohio 2019). “14(A)(3)(b) are in conflict, and applying the rule of lenity—codified in R.C. 2901.04(A) (“sections of the Revised Code defining offenses or penalties shall be strictly construed against the state, and liberally construed in favor of the accused”)—determined that R.”
State v. Whitfield, 2010 Ohio 2 (Ohio 2010). “The trial court determined that a plea of guilty was sufficient to satisfy the prior-conviction element. The court of appeals reversed, holding that a judgment entry of conviction was necessary to constitute a “conviction.”
State v. Stevens, 2014 Ohio 1932 (Ohio 2014). “{¶ 12} We are guided by the rules of statutory interpretation as codified in the rule of lenity, R.C. 2901.04(A). There, the legislature has made it clear that “sections of the Revised Code defining offenses or penalties shall be strictly construed against the state, and…”
— Ohio Rev. Code § 2901.04(A)(14) — 1 case
State v. Davenport, 2018 Ohio 2933 (Ohio Ct. App. 2018).
— Ohio Rev. Code § 2901.04(A)(4) — 1 case
State v. Davenport, 2019 Ohio 2297 (Ohio Ct. App. 2019).
— Ohio Rev. Code § 2901.04(A)(5)(a) — 1 case
State v. Barnes, 2013 Ohio 1298 (Ohio Ct. App. 2013).
— Ohio Rev. Code § 2901.04(B) — 19 cases
State v. Sowell (Slip Opinion), 2016 Ohio 8025 (Ohio 2016). “” See also R.C. 2901.04(B). {¶ 98} We conclude that the term “signed,” as used in Crim.”
State v. Joseph, 2010 Ohio 954 (Ohio 2010). “{¶ 30} Furthermore, R.C. 2901.04(A) requires that statutes defining offenses or penalties be strictly construed against the state and liberally in favor of the defendant.”
State v. Osie (Slip Opinion), 2014 Ohio 2966 (Ohio 2014). “” Because the term “criminal action or proceeding” was undefined in the statute, we interpreted the term to mean “a formal process involving a court.”
State v. White, 2012 Ohio 2583 (Ohio 2012). “Even if there were an ambiguity, meaning two reasonable ways of reading the statute, R.C. 2901.04 provides that we must read the language of the relevant statute not in favor of the government, but in favor of the accused.”
State v. Jamison, 552 N.E.2d 180 (Ohio 1990).
— Ohio Rev. Code § 2901.04(C) — 4 cases
State v. Vancleef, 2014 Ohio 2144 (Ohio Ct. App. 2014).
State v. Latham, 2012 Ohio 2106 (Ohio Ct. App. 2012).
State v. Staffrey, 2025 Ohio 2889 (Ohio 2025).
State v. Williams, 2019 Ohio 1104 (Ohio Ct. App. 2019).
— Ohio Rev. Code § 2901.04(D) — 3 cases
State v. Chappell, 2010 Ohio 5991 (Ohio 2010). “146, 150 Ohio Laws, Part V, 7787-7788 (modifying division (A) of R.C. 2901.04 by adding the phrase “or (D)” to the phrase “Except as otherwise provided in division (C) of this section” and enacting new division (D)).”
State v. Baum, 2017 Ohio 981 (Ohio Ct. App. 2017).
State v. Mullins, 2015 Ohio 3250 (Ohio Ct. App. 2015).
— Ohio Rev. Code § 2901.04(a) — 1 case
State v. Drake, 2012 Ohio 3718 (Ohio Ct. App. 2012).
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