Ohio Revised Code

Ohio Rev. Code § 2903.03 (2026)

Voluntary manslaughter

✓ current as of May 2026
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(A) No person, while under the influence of sudden passion or in a sudden fit of rage, either of which is brought on by serious provocation occasioned by the victim that is reasonably sufficient to incite the person into using deadly force, shall knowingly cause the death of another or the unlawful termination of another's pregnancy.

(B) No person, with a sexual motivation, shall violate division (A) of this section.

(C) Whoever violates this section is guilty of voluntary manslaughter, a felony of the first degree.

(D) As used in this section, "sexual motivation" has the same meaning as in section 2971.01 of the Revised Code.

Notes of Decisions
Cited in 426 cases (133 in the last 5 years), 1978–2026 · leading case: State v. Rhodes, 590 N.E.2d 261 (Ohio 1992).
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State v. Rhodes, 590 N.E.2d 261 (Ohio 1992). · cites it 15× “” R.C. 2903.03 defines voluntary manslaughter as a single offense that, under certain circumstances, permits a defendant to mitigate a charge of murder to manslaughter.”
State v. Johnson, 2010 Ohio 6314 (Ohio 2010). · cites it 4× “02(B) provides: {¶ b} “No person shall cause the death of another as a proximate result of the offender’s committing or attempting to commit an offense of violence that is a felony of the first or second degree and that is not a violation of section 2903.03 or 2903.04 of the…”
State v. Nicholson, 2024 Ohio 604 (Ohio 2024). · cites it 6× “There was no objective evidence presented on which a jury could have reasonably found that Nicholson had acted under the influence of “sudden passion” or was in a “sudden fit of rage,” R.C. 2903.03(A), brought about by serious provocation by the victims.”
State v. Tyler, 553 N.E.2d 576 (Ohio 1990). · cites it 6× “” While appellant did not specify whether he meant voluntary or involuntary manslaughter, he argued that the jury should be instructed on “manslaughter” because of the possible existence of provocation.”
State v. Thompson (Slip Opinion), 2014 Ohio 4751 (Ohio 2014). · cites it 4× “03 defines the crime of voluntary manslaughter as follows: (A) No person, while under the influence of sudden passion or in a sudden fit of rage, either of which is brought on by serious provocation occasioned by the victim that is reasonably sufficient to incite the person into…”
State v. Messenger, 2022 Ohio 4562 (Ohio 2022). · cites it 2× “(B) No person shall cause the death of another as a proximate result of the offender’s committing or attempting to commit an offense of violence that is a felony of the first or second degree and that is not a violation of section 2903.03 or 2903.04 of the Revised Code.”
State v. Conway, 108 Ohio St. 3d 214 (Ohio 2006). · cites it 3× “R.C. 2903.03(A), which defines voluntary manslaughter, provides, “No person, while under the influence of sudden passion or in a sudden fit of rage, either of which is brought on by serious provocation occasioned by the victim that is reasonably sufficient to incite the person…”
State v. Miku, 2018 Ohio 1584 (Ohio Ct. App. 2018). · cites it 4× “22(B)(1) and/or (B)(2), which read in toto as follows: (B) No person shall do any of the following to a child under eighteen years of age or a mentally or physically handicapped child under twenty-one years of age: (1) Abuse the child; (2) Torture or cruelly abuse the child[.”
Engle v. Isaac, 456 U.S. 107 (1982). · cites it 2× “[7] Voluntary manslaughter is "knowingly caus[ing] the death of another" while under "extreme emotional stress brought on by serious provocation reasonably sufficient to incite [the defendant] into using deadly force.”
State v. Sheline, 2019 Ohio 528 (Ohio Ct. App. 2019). · cites it 2× “(B) No person shall cause the death of another as a proximate result of the offender’s committing or attempting to commit an offense of violence that is a felony of the first or second degree and that is not a violation of section 2903.03 or 2903.04 of the Revised Code.”
State v. Winbush, 2017 Ohio 696 (Ohio Ct. App. 2017). · cites it 2× “This statute provides that: No person shall cause the death of another as a proximate result of the offender's committing or attempting to commit an offense of violence that is a felony of the first or second degree and that is not a violation of section 2903.03 or 2903.04 of…”
State v. Hanford, 2019 Ohio 2987 (Ohio Ct. App. 2019). · cites it 5× “(B) No person shall cause the death of another as a proximate result of the offender’s committing or attempting to commit an offense of violence that is a felony of the first or second degree and that is not a violation of section 2903.03 or 2903.04 of the Revised Code.”
Show all 426 citing cases →
— Ohio Rev. Code § 2903.03(A) — 179 cases
State v. Nicholson, 2024 Ohio 604 (Ohio 2024). “There was no objective evidence presented on which a jury could have reasonably found that Nicholson had acted under the influence of “sudden passion” or was in a “sudden fit of rage,” R.C. 2903.03(A), brought about by serious provocation by the victims.”
State v. Conway, 108 Ohio St. 3d 214 (Ohio 2006). “R.C. 2903.03(A), which defines voluntary manslaughter, provides, “No person, while under the influence of sudden passion or in a sudden fit of rage, either of which is brought on by serious provocation occasioned by the victim that is reasonably sufficient to incite the person…”
State v. Rhodes, 590 N.E.2d 261 (Ohio 1992). “” R.C. 2903.03 defines voluntary manslaughter as a single offense that, under certain circumstances, permits a defendant to mitigate a charge of murder to manslaughter.”
State v. Thompson (Slip Opinion), 2014 Ohio 4751 (Ohio 2014). “03 defines the crime of voluntary manslaughter as follows: (A) No person, while under the influence of sudden passion or in a sudden fit of rage, either of which is brought on by serious provocation occasioned by the victim that is reasonably sufficient to incite the person into…”
State v. Knuff, 2024 Ohio 902 (Ohio 2024).
— Ohio Rev. Code § 2903.03(A)(1) — 3 cases
State v. Jones, 2023 Ohio 380 (Ohio Ct. App. 2023).
Sowell v. Collins, 557 F. Supp. 2d 843 (S.D. Ohio 2008).
Lachman v. Farmers Ins. of Columbus, 2012 Ohio 85 (Ohio Ct. App. 2012).
— Ohio Rev. Code § 2903.03(A)(1)(a) — 1 case
State v. Rangel, 2016 Ohio 7148 (Ohio Ct. App. 2016).
— Ohio Rev. Code § 2903.03(A)(1)(d) — 1 case
State v. Wilson, 2012 Ohio 102 (Ohio Ct. App. 2012).
— Ohio Rev. Code § 2903.03(B) — 7 cases
State v. Bruce, 866 N.E.2d 44 (Ohio Ct. App. 2007).
State v. Kvasne, 862 N.E.2d 171 (Ohio Ct. App. 2006).
State v. Kerns, 829 N.E.2d 700 (Ohio Ct. App. 2005).
State v. Wells, 728 N.E.2d 408 (Ohio Ct. App. 1999).
State v. Davis, 2013 Ohio 1748 (Ohio 2013).
— Ohio Rev. Code § 2903.03(B)(D) — 1 case
Carter v. LaRose (N.D. Ohio 2021).
— Ohio Rev. Code § 2903.03(C) — 2 cases
State v. Underwood, 2024 Ohio 2273 (Ohio Ct. App. 2024).
State v. Lakes, 2022 Ohio 703 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 2903.03(D) — 1 case
State v. Evans, 3 Ohio App. Unrep. 177 (Ohio Ct. App. 1990).
— Ohio Rev. Code § 2903.03(D)(2)(b) — 1 case
State v. Jones, 2023 Ohio 380 (Ohio Ct. App. 2023).
— Ohio Rev. Code § 2903.03(F) — 1 case
State v. Little, 2023 Ohio 4098 (Ohio Ct. App. 2023).
— Ohio Rev. Code § 2903.03(a)(2) — 1 case
State v. Farley, Unpublished Decision (5-16-2005), 2005 Ohio 2367 (Ohio Ct. App. 2005).
— Ohio Rev. Code § 2903.03(c) — 1 case
Anne Crabbs v. Zach Scott (6th Cir. 2020).
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