Ohio Rev. Code » Chapter 2901
Ohio Revised Code

Ohio Rev. Code § 2901.06 (2026)

Battered woman syndrome evidence

✓ current as of May 2026
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Effective:
November 5, 1990
Latest Legislation:
House Bill 484 - 118th General Assembly
PDF:
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(A) The general assembly hereby declares that it recognizes both of the following, in relation to the "battered woman syndrome:"

(1) That the syndrome currently is a matter of commonly accepted scientific knowledge;

(2) That the subject matter and details of the syndrome are not within the general understanding or experience of a person who is a member of the general populace and are not within the field of common knowledge.

(B) If a person is charged with an offense involving the use of force against another and the person, as a defense to the offense charged, raises the affirmative defense of self-defense, the person may introduce expert testimony of the "battered woman syndrome" and expert testimony that the person suffered from that syndrome as evidence to establish the requisite belief of an imminent danger of death or great bodily harm that is necessary, as an element of the affirmative defense, to justify the person's use of the force in question. The introduction of any expert testimony under this division shall be in accordance with the Ohio Rules of Evidence.
Notes of Decisions
Cited in 31 cases (5 in the last 5 years), 1956–2025 · leading case: State v. Goff, 2010 Ohio 6317 (Ohio 2010).
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State v. Goff, 2010 Ohio 6317 (Ohio 2010). · cites it 12× “06 that battered-woman syndrome “is a matter of commonly accepted scientific 10 January Term, 2010 knowledge” and that “the subject matter and details of the syndrome are not within the general understanding or experience of a person who is a member of the general populace and…”
State v. Haines, 2006 Ohio 6711 (Ohio 2006). · cites it 10× “{¶ 36} The same year of this court’s decision in Koss, the General Assembly enacted R.C. 2901.06, which recognizes the value of battered-woman- syndrome testimony and sets forth that it may be employed in self-defense cases: {¶ 37} “(A) The general assembly hereby declares that…”
State v. Daws, 662 N.E.2d 805 (Ohio Ct. App. 1994). · cites it 7× “484 was enacted as R.C. 2901.06, which states as follows: “(A) The general assembly hereby declares that it recognizes both of the following, in relation to the ‘battered woman syndrome:’ “(1) That the syndrome currently is a matter of commonly accepted scientific knowledge;…”
State v. Eaton, 249 N.E.2d 897 (Ohio 1969). · cites it 4× “” Section 2901.06, Revised Code, defines manslaughter,' *160 as follows: “No person shall unlawfully kill another.”
State v. Rizer, 2011 Ohio 5702 (Ohio Ct. App. 2011). · cites it 3× “{¶13} “After Koss, the General Assembly recognized in R.C. 2901.06 that battered-woman syndrome ‘is a matter of commonly accepted scientific knowledge’ and that ‘the subject matter and details of the syndrome are not within the general Meigs App.”
State v. Sallie, 693 N.E.2d 267 (Ohio 1998). “R.C. 2901.06. Ohio has adopted a subjective test to determine whether a defendant properly acted in self-defense.”
State v. Koss, 551 N.E.2d 970 (Ohio 1990). “39 be amended and sections 2901.06 and 2945.391 of the Revised Code be enacted to read as follows: “Sec.”
State v. Nemeth, 694 N.E.2d 1332 (Ohio 1998). “The General Assembly enacted R.C. 2901.06(A)(1) in 1990, which declares that battered woman syndrome is currently a matter of “commonly accepted scientific knowledge.”
State v. Sallie, 1998 Ohio 343 (Ohio 1998). “R.C. 2901.06. Ohio has adopted a subjective test to determine whether a defendant properly acted in self-defense.”
State v. Manning, 598 N.E.2d 25 (Ohio Ct. App. 1991). · cites it 2× “R.C. 2901.06. During the defense case, Lynne B.”
State v. McCallum, 2021 Ohio 2938 (Ohio Ct. App. 2021). “R.C. 2901.06 provides: (A) The general assembly hereby declares that it recognizes both of the following, in relation to the "battered woman syndrome:" No.”
State v. Butler, 227 N.E.2d 627 (Ohio 1967). · cites it 2× “Section 2901.06, Revised Code, captioned, “Manslaughter in the first degree,” is as follows: “No person shall unlawfully kill another.”
Show all 31 citing cases →
— Ohio Rev. Code § 2901.06(A) — 2 cases
State v. Haines, 2006 Ohio 6711 (Ohio 2006). “{¶ 36} The same year of this court’s decision in Koss, the General Assembly enacted R.C. 2901.06, which recognizes the value of battered-woman- syndrome testimony and sets forth that it may be employed in self-defense cases: {¶ 37} “(A) The general assembly hereby declares that…”
State v. Cleavenger, 2022 Ohio 2942 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 2901.06(A)(1) — 4 cases
State v. Goff, 2010 Ohio 6317 (Ohio 2010). “06 that battered-woman syndrome “is a matter of commonly accepted scientific 10 January Term, 2010 knowledge” and that “the subject matter and details of the syndrome are not within the general understanding or experience of a person who is a member of the general populace and…”
State v. Nemeth, 694 N.E.2d 1332 (Ohio 1998). “The General Assembly enacted R.C. 2901.06(A)(1) in 1990, which declares that battered woman syndrome is currently a matter of “commonly accepted scientific knowledge.”
State v. Rizer, 2011 Ohio 5702 (Ohio Ct. App. 2011). “{¶13} “After Koss, the General Assembly recognized in R.C. 2901.06 that battered-woman syndrome ‘is a matter of commonly accepted scientific knowledge’ and that ‘the subject matter and details of the syndrome are not within the general Meigs App.”
State v. Nemeth, 1998 Ohio 376 (Ohio 1998).
— Ohio Rev. Code § 2901.06(B) — 9 cases
State v. Haines, 2006 Ohio 6711 (Ohio 2006). “{¶ 36} The same year of this court’s decision in Koss, the General Assembly enacted R.C. 2901.06, which recognizes the value of battered-woman- syndrome testimony and sets forth that it may be employed in self-defense cases: {¶ 37} “(A) The general assembly hereby declares that…”
State v. Goff, 2010 Ohio 6317 (Ohio 2010). “06 that battered-woman syndrome “is a matter of commonly accepted scientific 10 January Term, 2010 knowledge” and that “the subject matter and details of the syndrome are not within the general understanding or experience of a person who is a member of the general populace and…”
State v. Rizer, 2011 Ohio 5702 (Ohio Ct. App. 2011). “{¶13} “After Koss, the General Assembly recognized in R.C. 2901.06 that battered-woman syndrome ‘is a matter of commonly accepted scientific knowledge’ and that ‘the subject matter and details of the syndrome are not within the general Meigs App.”
State v. Manning, 598 N.E.2d 25 (Ohio Ct. App. 1991). “R.C. 2901.06. During the defense case, Lynne B.”
State v. Pargeon, 582 N.E.2d 665 (Ohio Ct. App. 1991).
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