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Ohio Revised Code

Ohio Rev. Code § 2901.12 (2026)

Venue of criminal cases

✓ current as of May 2026
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Effective:
March 23, 2015
Latest Legislation:
House Bill 290 - 130th General Assembly
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(A) The trial of a criminal case in this state shall be held in a court having jurisdiction of the subject matter, and, except in cases of emergency under section 1901.028, 1907.04, 2301.04, or 2501.20 of the Revised Code, in the territory of which the offense or any element of the offense was committed.

(B) When the offense or any element of the offense was committed in an aircraft, motor vehicle, train, watercraft, or other vehicle, in transit, and it cannot reasonably be determined in which jurisdiction the offense was committed, the offender may be tried in any jurisdiction through which the aircraft, motor vehicle, train, watercraft, or other vehicle passed.

(C) When the offense involved the unlawful taking or receiving of property or the unlawful taking or enticing of another, the offender may be tried in any jurisdiction from which or into which the property or victim was taken, received, or enticed.

(D) When the offense is conspiracy, attempt, or complicity cognizable under division (A)(2) of section 2901.11 of the Revised Code, the offender may be tried in any jurisdiction in which the conspiracy, attempt, complicity, or any of its elements occurred. If an offense resulted outside this state from the conspiracy, attempt, or complicity, that resulting offense also may be tried in any jurisdiction in which the conspiracy, attempt, complicity, or any of the elements of the conspiracy, attempt, or complicity occurred.

(E) When the offense is conspiracy or attempt cognizable under division (A)(3) of section 2901.11 of the Revised Code, the offender may be tried in any jurisdiction in which the offense that was the object of the conspiracy or attempt, or any element of that offense, was intended to or could have taken place. When the offense is complicity cognizable under division (A)(3) of section 2901.11 of the Revised Code, the offender may be tried in any jurisdiction in which the principal offender may be tried.

(F) When an offense is considered to have been committed in this state while the offender was out of this state, and the jurisdiction in this state in which the offense or any material element of the offense was committed is not reasonably ascertainable, the offender may be tried in any jurisdiction in which the offense or element reasonably could have been committed.

(G) When it appears beyond a reasonable doubt that an offense or any element of an offense was committed in any of two or more jurisdictions, but it cannot reasonably be determined in which jurisdiction the offense or element was committed, the offender may be tried in any of those jurisdictions.

(H) When an offender, as part of a course of criminal conduct, commits offenses in different jurisdictions, the offender may be tried for all of those offenses in any jurisdiction in which one of those offenses or any element of one of those offenses occurred. Without limitation on the evidence that may be used to establish the course of criminal conduct, any of the following is prima-facie evidence of a course of criminal conduct:

(1) The offenses involved the same victim, or victims of the same type or from the same group.

(2) The offenses were committed by the offender in the offender's same employment, or capacity, or relationship to another.

(3) The offenses were committed as part of the same transaction or chain of events, or in furtherance of the same purpose or objective.

(4) The offenses were committed in furtherance of the same conspiracy.

(5) The offenses involved the same or a similar modus operandi.

(6) The offenses were committed along the offender's line of travel in this state, regardless of the offender's point of origin or destination.

(I)(1) When the offense involves a computer, computer system, computer network, telecommunication, telecommunications device, telecommunications service, or information service, the offender may be tried in any jurisdiction containing any location of the computer, computer system, or computer network of the victim of the offense, in any jurisdiction from which or into which, as part of the offense, any writing, data, or image is disseminated or transmitted by means of a computer, computer system, computer network, telecommunication, telecommunications device, telecommunications service, or information service, or in any jurisdiction in which the alleged offender commits any activity that is an essential part of the offense.

(2) As used in this section, "computer," "computer system," "computer network," "information service," "telecommunication," "telecommunications device," "telecommunications service," "data," and "writing" have the same meanings as in section 2913.01 of the Revised Code.

(J) When the offense involves the death of a person, and it cannot reasonably be determined in which jurisdiction the offense was committed, the offender may be tried in the jurisdiction in which the dead person's body or any part of the dead person's body was found.

(K) Notwithstanding any other requirement for the place of trial, venue may be changed, upon motion of the prosecution, the defense, or the court, to any court having jurisdiction of the subject matter outside the county in which trial otherwise would be held, when it appears that a fair and impartial trial cannot be held in the jurisdiction in which trial otherwise would be held, or when it appears that trial should be held in another jurisdiction for the convenience of the parties and in the interests of justice.
Notes of Decisions
Cited in 288 cases (75 in the last 5 years), 1957–2026 · leading case: State v. Armengau, 2017 Ohio 4452 (Ohio Ct. App. 2017).
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State v. Armengau, 2017 Ohio 4452 (Ohio Ct. App. 2017). · cites it 42× “Lastly, appellant was on notice that the state would establish venue by proving the conduct occurred in Franklin County "or otherwise properly venued under R.C. 2901.12, the defendant, as part of a criminal course of conduct as defined in R.”
State v. Moore, 2022 Ohio 1460 (Ohio 2022). · cites it 36× “{¶ 8} The trial court denied Moore’s motion and held that venue was proper under R.C. 2901.12. The jury then found Moore guilty on all three charges, and the trial court sentenced him to 22 years in prison.”
State v. Jackson (Slip Opinion), 2014 Ohio 3707 (Ohio 2014). · cites it 14× “” {¶ 122} R.C. 2901.12, Ohio’s venue statute, provides: (A) The trial of a criminal case in this state shall be held in a court having jurisdiction of the subject matter, and in the territory of which the offense or any element of the offense was committed.”
State v. Brentlinger, 2017 Ohio 2588 (Ohio Ct. App. 2017). · cites it 12× “* * * (H) When an offender, as part of a course of criminal conduct, commits offenses in different jurisdictions, the offender may be tried for all of those offenses in any jurisdiction in which one of those offenses or any element of one of those offenses occurred.”
State v. Birt, 2013 Ohio 1379 (Ohio Ct. App. 2013). · cites it 11× “R.C. 2901.12 further provides that when an offender commits offenses in different jurisdictions as part of a course of criminal conduct, venue lies for all the offenses in any jurisdiction in which the offender committed one of the offenses or any element of one of those…”
State v. Headley, 453 N.E.2d 716 (Ohio 1983). · cites it 7× “Generally, this rule is preserved in R.C. 2901.12, Ohio’s venue statute, although the Committee Comment to that statute notes that provision is also made for the mobile offender whose course of criminal conduct affects a number of jurisdictions.”
State v. Brown, 2017 Ohio 8416 (Ohio Ct. App. 2017). · cites it 4× “12(B) inapplicable. {¶ 33} "Venue is not a material element of any crime, but is a fact that must be proven beyond a reasonable doubt unless the defendant waives it.”
State v. Yavorcik, 2018 Ohio 1824 (Ohio Ct. App. 2018). · cites it 11× “29, R.C. 2901.12, and the well-established common-law rule set forth in cases like [ State v.”
State v. Maurer, 473 N.E.2d 768 (Ohio 1984). · cites it 4× “29 concerns the mechanism for effecting a change of venue if so ordered by the court: “When a change of venue is ordered pursuant to section 2901.12 of the Revised Code, the clerk of the court in which the cause is pending shall make a certified transcript of the proceedings in…”
State v. Foreman (Slip Opinion), 2021 Ohio 3409 (Ohio 2021). · cites it 10× “] Criminal law—Venue—R.C. 2901.12—Sufficiency of the evidence—Possession of drugs—Mere presence of drug metabolites in defendant’s body, without more, is insufficient evidence to establish venue in the charging county for drug-possession offense—Court of appeals’ judgment…”
State v. Foreman, 2020 Ohio 3145 (Ohio Ct. App. 2020). · cites it 35× “Under R.C. 2901.12(A), venue is generally placed in the territory in which an offense is committed.”
State v. Potee, 2017 Ohio 2926 (Ohio Ct. App. 2017). · cites it 7× “" R.C. 2901.12 embodies the constitutional protections provided by the Ohio Constitution's guarantee to its citizens to "a speedy trial by an impartial jury of the county in which the offense is alleged to have been committed * * *.”
Show all 288 citing cases →
— Ohio Rev. Code § 2901.12(1) — 2 cases
State v. Maurer, 473 N.E.2d 768 (Ohio 1984). “29 concerns the mechanism for effecting a change of venue if so ordered by the court: “When a change of venue is ordered pursuant to section 2901.12 of the Revised Code, the clerk of the court in which the cause is pending shall make a certified transcript of the proceedings in…”
State v. Spirko, 570 N.E.2d 229 (Ohio 1991).
— Ohio Rev. Code § 2901.12(A) — 107 cases
State v. Brentlinger, 2017 Ohio 2588 (Ohio Ct. App. 2017). “* * * (H) When an offender, as part of a course of criminal conduct, commits offenses in different jurisdictions, the offender may be tried for all of those offenses in any jurisdiction in which one of those offenses or any element of one of those offenses occurred.”
State v. Foreman, 2020 Ohio 3145 (Ohio Ct. App. 2020). “Under R.C. 2901.12(A), venue is generally placed in the territory in which an offense is committed.”
State v. Moore, 2022 Ohio 1460 (Ohio 2022). “{¶ 8} The trial court denied Moore’s motion and held that venue was proper under R.C. 2901.12. The jury then found Moore guilty on all three charges, and the trial court sentenced him to 22 years in prison.”
State v. Carpenter, 2019 Ohio 58 (Ohio Ct. App. 2019).
State v. Foreman (Slip Opinion), 2021 Ohio 3409 (Ohio 2021). “] Criminal law—Venue—R.C. 2901.12—Sufficiency of the evidence—Possession of drugs—Mere presence of drug metabolites in defendant’s body, without more, is insufficient evidence to establish venue in the charging county for drug-possession offense—Court of appeals’ judgment…”
— Ohio Rev. Code § 2901.12(A)(12) — 1 case
State v. Ramsden-Cooke, 2024 Ohio 4833 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2901.12(B) — 8 cases
State v. Brown, 2017 Ohio 8416 (Ohio Ct. App. 2017). “12(B) inapplicable. {¶ 33} "Venue is not a material element of any crime, but is a fact that must be proven beyond a reasonable doubt unless the defendant waives it.”
State v. Lester, 2009 Ohio 4225 (Ohio 2009).
State v. Barnes, 2023 Ohio 353 (Ohio Ct. App. 2023).
State v. Wright, 2016 Ohio 7654 (Ohio Ct. App. 2016).
State v. Stutz, 2020 Ohio 6959 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2901.12(C) — 11 cases
State v. Dillon, 2020 Ohio 5031 (Ohio Ct. App. 2020).
State v. Williams, 2015 Ohio 3932 (Ohio Ct. App. 2015).
State v. Andrews, 772 N.E.2d 167 (Ohio Ct. App. 2002).
State v. Giffin, 575 N.E.2d 887 (Ohio Ct. App. 1991).
State v. Freeman, 2014 Ohio 1013 (Ohio Ct. App. 2014).
— Ohio Rev. Code § 2901.12(D) — 1 case
State v. Holloway, 2024 Ohio 3189 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2901.12(E) — 9 cases
State v. Leonard, 104 Ohio St. 3d 54 (Ohio 2004).
State v. Coley, 754 N.E.2d 1129 (Ohio 2001).
State v. Mammone (Slip Opinion), 2014 Ohio 1942 (Ohio 2014).
State v. Getsy, 702 N.E.2d 866 (Ohio 1998).
State v. Cunningham, 2004 Ohio 7007 (Ohio 2004).
— Ohio Rev. Code § 2901.12(F) — 1 case
State v. Pellin, 2012 Ohio 5342 (Ohio Ct. App. 2012).
— Ohio Rev. Code § 2901.12(G) — 29 cases
State v. Armengau, 2017 Ohio 4452 (Ohio Ct. App. 2017). “Lastly, appellant was on notice that the state would establish venue by proving the conduct occurred in Franklin County "or otherwise properly venued under R.C. 2901.12, the defendant, as part of a criminal course of conduct as defined in R.”
State v. Moore, 2022 Ohio 1460 (Ohio 2022). “{¶ 8} The trial court denied Moore’s motion and held that venue was proper under R.C. 2901.12. The jury then found Moore guilty on all three charges, and the trial court sentenced him to 22 years in prison.”
State v. Headley, 453 N.E.2d 716 (Ohio 1983). “Generally, this rule is preserved in R.C. 2901.12, Ohio’s venue statute, although the Committee Comment to that statute notes that provision is also made for the mobile offender whose course of criminal conduct affects a number of jurisdictions.”
State v. Foreman, 2020 Ohio 3145 (Ohio Ct. App. 2020). “Under R.C. 2901.12(A), venue is generally placed in the territory in which an offense is committed.”
State v. Lewis, 2020 Ohio 6894 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2901.12(H) — 101 cases
State v. Armengau, 2017 Ohio 4452 (Ohio Ct. App. 2017). “Lastly, appellant was on notice that the state would establish venue by proving the conduct occurred in Franklin County "or otherwise properly venued under R.C. 2901.12, the defendant, as part of a criminal course of conduct as defined in R.”
State v. Moore, 2022 Ohio 1460 (Ohio 2022). “{¶ 8} The trial court denied Moore’s motion and held that venue was proper under R.C. 2901.12. The jury then found Moore guilty on all three charges, and the trial court sentenced him to 22 years in prison.”
State v. Jackson (Slip Opinion), 2014 Ohio 3707 (Ohio 2014). “” {¶ 122} R.C. 2901.12, Ohio’s venue statute, provides: (A) The trial of a criminal case in this state shall be held in a court having jurisdiction of the subject matter, and in the territory of which the offense or any element of the offense was committed.”
State v. Birt, 2013 Ohio 1379 (Ohio Ct. App. 2013). “R.C. 2901.12 further provides that when an offender commits offenses in different jurisdictions as part of a course of criminal conduct, venue lies for all the offenses in any jurisdiction in which the offender committed one of the offenses or any element of one of those…”
State v. Yavorcik, 2018 Ohio 1824 (Ohio Ct. App. 2018). “29, R.C. 2901.12, and the well-established common-law rule set forth in cases like [ State v.”
— Ohio Rev. Code § 2901.12(H)(1) — 21 cases
State v. Armengau, 2017 Ohio 4452 (Ohio Ct. App. 2017). “Lastly, appellant was on notice that the state would establish venue by proving the conduct occurred in Franklin County "or otherwise properly venued under R.C. 2901.12, the defendant, as part of a criminal course of conduct as defined in R.”
State v. Jackson (Slip Opinion), 2014 Ohio 3707 (Ohio 2014). “” {¶ 122} R.C. 2901.12, Ohio’s venue statute, provides: (A) The trial of a criminal case in this state shall be held in a court having jurisdiction of the subject matter, and in the territory of which the offense or any element of the offense was committed.”
State v. Edwards, 2017 Ohio 7231 (Ohio Ct. App. 2017).
State v. Birt, 2013 Ohio 1379 (Ohio Ct. App. 2013). “R.C. 2901.12 further provides that when an offender commits offenses in different jurisdictions as part of a course of criminal conduct, venue lies for all the offenses in any jurisdiction in which the offender committed one of the offenses or any element of one of those…”
State v. Young, 2017 Ohio 1400 (Ohio Ct. App. 2017).
— Ohio Rev. Code § 2901.12(H)(1)(2) — 1 case
State v. Birt, 2013 Ohio 1379 (Ohio Ct. App. 2013). “R.C. 2901.12 further provides that when an offender commits offenses in different jurisdictions as part of a course of criminal conduct, venue lies for all the offenses in any jurisdiction in which the offender committed one of the offenses or any element of one of those…”
— Ohio Rev. Code § 2901.12(H)(2) — 4 cases
State v. Armengau, 2017 Ohio 4452 (Ohio Ct. App. 2017). “Lastly, appellant was on notice that the state would establish venue by proving the conduct occurred in Franklin County "or otherwise properly venued under R.C. 2901.12, the defendant, as part of a criminal course of conduct as defined in R.”
State v. Barron, 2022 Ohio 102 (Ohio Ct. App. 2022).
State v. Moore, 2012 Ohio 3604 (Ohio Ct. App. 2012).
Barron v. Warden, Madison Corr. Inst. (S.D. Ohio 2024).
— Ohio Rev. Code § 2901.12(H)(3) — 24 cases
State v. Potee, 2017 Ohio 2926 (Ohio Ct. App. 2017). “" R.C. 2901.12 embodies the constitutional protections provided by the Ohio Constitution's guarantee to its citizens to "a speedy trial by an impartial jury of the county in which the offense is alleged to have been committed * * *.”
State v. Armengau, 2017 Ohio 4452 (Ohio Ct. App. 2017). “Lastly, appellant was on notice that the state would establish venue by proving the conduct occurred in Franklin County "or otherwise properly venued under R.C. 2901.12, the defendant, as part of a criminal course of conduct as defined in R.”
State v. Brentlinger, 2017 Ohio 2588 (Ohio Ct. App. 2017). “* * * (H) When an offender, as part of a course of criminal conduct, commits offenses in different jurisdictions, the offender may be tried for all of those offenses in any jurisdiction in which one of those offenses or any element of one of those offenses occurred.”
State v. Crossty, 2017 Ohio 8267 (Ohio Ct. App. 2017).
State v. Carpenter, 2019 Ohio 58 (Ohio Ct. App. 2019).
— Ohio Rev. Code § 2901.12(H)(4) — 1 case
State v. Yavorcik, 2018 Ohio 1824 (Ohio Ct. App. 2018). “29, R.C. 2901.12, and the well-established common-law rule set forth in cases like [ State v.”
— Ohio Rev. Code § 2901.12(H)(5) — 3 cases
State v. Armengau, 2017 Ohio 4452 (Ohio Ct. App. 2017). “Lastly, appellant was on notice that the state would establish venue by proving the conduct occurred in Franklin County "or otherwise properly venued under R.C. 2901.12, the defendant, as part of a criminal course of conduct as defined in R.”
State v. Beuke, 526 N.E.2d 274 (Ohio 1988).
State v. Miller, 2014 Ohio 4998 (Ohio Ct. App. 2014).
— Ohio Rev. Code § 2901.12(H)(6) — 1 case
State v. Brentlinger, 2017 Ohio 2588 (Ohio Ct. App. 2017). “* * * (H) When an offender, as part of a course of criminal conduct, commits offenses in different jurisdictions, the offender may be tried for all of those offenses in any jurisdiction in which one of those offenses or any element of one of those offenses occurred.”
— Ohio Rev. Code § 2901.12(I) — 1 case
State v. Godschild, 2025 Ohio 5085 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2901.12(I)(1) — 11 cases
State v. Pyles, 2018 Ohio 4034 (Ohio Ct. App. 2018).
State v. Stefan, 2018 Ohio 266 (Ohio Ct. App. 2018).
Brecksville v. Sadaghiani, 2021 Ohio 2443 (Ohio Ct. App. 2021).
State v. Brady, 2024 Ohio 269 (Ohio Ct. App. 2024).
State v. Smith, 2018 Ohio 5121 (Ohio Ct. App. 2018).
— Ohio Rev. Code § 2901.12(I)(2) — 1 case
State v. Schultz, 2024 Ohio 405 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2901.12(J) — 9 cases
State v. Mills, 582 N.E.2d 972 (Ohio 1992).
State v. Tinch, 616 N.E.2d 529 (Ohio Ct. App. 1992).
State v. Thompson, 514 N.E.2d 407 (Ohio 1987).
State v. Warner, 564 N.E.2d 18 (Ohio 1990).
State v. Ritchey, 2023 Ohio 1625 (Ohio Ct. App. 2023).
— Ohio Rev. Code § 2901.12(K) — 22 cases
State v. Trimble, 2009 Ohio 2961 (Ohio 2009).
State v. Armengau, 2017 Ohio 4452 (Ohio Ct. App. 2017). “Lastly, appellant was on notice that the state would establish venue by proving the conduct occurred in Franklin County "or otherwise properly venued under R.C. 2901.12, the defendant, as part of a criminal course of conduct as defined in R.”
State v. Conway, 848 N.E.2d 810 (Ohio 2006).
State v. Adams, 103 Ohio St. 3d 508 (Ohio 2004).
State v. Mammone (Slip Opinion), 2014 Ohio 1942 (Ohio 2014).
— Ohio Rev. Code § 2901.12(Y) — 1 case
State v. Sutton, 2025 Ohio 2469 (Ohio Ct. App. 2025).
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