Ohio Revised Code

Ohio Rev. Code § 2903.34 (2026)

Patient abuse or neglect

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(A) No person who owns, operates, or administers, or who is an agent or employee of, a care facility shall do any of the following:

(1) Commit abuse against a resident or patient of the facility;

(2) Commit gross neglect against a resident or patient of the facility;

(3) Commit neglect against a resident or patient of the facility.

(B)(1) A person who relies upon treatment by spiritual means through prayer alone, in accordance with the tenets of a recognized religious denomination, shall not be considered neglected under division (A)(3) of this section for that reason alone.

(2) It is an affirmative defense to a charge of gross neglect or neglect under this section that the actor's conduct was committed in good faith solely because the actor was ordered to commit the conduct by a person with supervisory authority over the actor.

(C) Whoever violates division (A)(1) of this section is guilty of patient abuse, a felony of the fourth degree. If the offender previously has been convicted of, or pleaded guilty to, any violation of this section, patient abuse is a felony of the third degree.

(D) Whoever violates division (A)(2) of this section is guilty of gross patient neglect, a misdemeanor of the first degree. If the offender previously has been convicted of, or pleaded guilty to, any violation of this section, gross patient neglect is a felony of the fifth degree.

(E) Whoever violates division (A)(3) of this section is guilty of patient neglect, a misdemeanor of the second degree. If the offender previously has been convicted of or pleaded guilty to any violation of this section, patient neglect is a felony of the fifth degree.

Notes of Decisions
Cited in 26 cases (13 in the last 5 years), 1991–2026 · leading case: State v. Ridley, 2022-Ohio-2561.
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State v. Ridley, 2022-Ohio-2561. · cites it 2× “{¶1} Following a bench trial, defendant-appellant Natalie Ridley was convicted of patient abuse under R.C. 2903.34(A)(1). She presents three assignments of error.”
State v. Evans, 2014-Ohio-2081. · cites it 5× “Facts and Procedural History {¶ 2} On November 5, 2012, appellee filed an application requesting the trial court seal the record of her conviction for attempted patient abuse in violation of R.C. 2903.34, a first-degree misdemeanor.”
State v. Webb, 2025-Ohio-456. · cites it 3× “34 provides, in relevant part: (A) No person who owns, operates, or administers, or who is an agent or employee of, a care facility shall do any of the following: (1) Commit abuse against a resident or patient of the facility.”
State v. Briscoe, 617 N.E.2d 747 (Ohio Ct. App. 8th Dist. 1992). · cites it 3× “Clyde Briscoe, defendant-appellant, appeals his conviction of one count of attempted patient abuse under R.C. 2903.34 and 2923.02. From October 1989 to March 1990, Clyde Briscoe was employed as a habilitation aide at the Northeast Care Center (“Northeast”), an institution for…”
State v. Simmons, 2011-Ohio-2068. · cites it 2× “{¶ 5} Defendant was indicted on one count of patient abuse in violation of R.C. 2903.34.(A)(1). Defendant filed a motion to suppress evidence of a surveillance video from inside the nursing home.”
State v. Moore, 2019-Ohio-1467. · cites it 2× “161, of division (A)(1) of section 2903.34, of division (A)(1), (2), or (3) of section 2911.”
State v. Johnson, 2020-Ohio-2676. · cites it 2× “161, of division (A)(1) of section 2903.34, of division (A)(1), (2), or (3) of section 2911.”
State v. Caraballo, 2012-Ohio-5725. · cites it 4× “: {¶1} Defendant-appellant Virgen Caraballo appeals from her convictions and the consecutive sentences imposed after she pleaded guilty in the Cuyahoga County Court of Common Pleas to seven counts of patient abuse in violation of R.C. 2903.34(A)(1). {¶2} Caraballo presents five…”
State v. Hustead, 615 N.E.2d 1081 (Ohio Ct. App. 4th Dist. 1992). · cites it 2× “This is an appeal from a jury verdict of the Ross County Court of Common Pleas which found Kathleen Hustead guilty of violating R.C. 2903.34, patient abuse. Hustead worked in a nursing home.”
State v. Szozda, 2022-Ohio-2294. · cites it 2× “161, of division (A)(1) of section 2903.34, of division (A)(1), (2), or (3) of section 2911.”
State v. Kamara, 2023-Ohio-2146. · cites it 2× “161, of division (A)(1) of section 2903.34, of division (A)(1), (2), or (3) of section 2911.”
State v. Curry, 601 N.E.2d 176 (Ohio Ct. App. 8th Dist. 1991). · cites it 4× “I On August 29,1989, defendant, an employee of Warrensville Developmental Center, was indicted for one count of patient abuse, in violation of R.C. 2903.34. Defendant pleaded not guilty and the matter proceeded to a bench trial on December 11, 1989.”
Show all 26 citing cases →
Ohio Rev. Code § 2903.34(A): 1 case
State v. Curry, 601 N.E.2d 176 (Ohio Ct. App. 8th Dist. 1991). “I On August 29,1989, defendant, an employee of Warrensville Developmental Center, was indicted for one count of patient abuse, in violation of R.C. 2903.34. Defendant pleaded not guilty and the matter proceeded to a bench trial on December 11, 1989.”
Ohio Rev. Code § 2903.34(A)(1): 7 cases
State v. Ridley, 2022-Ohio-2561. “{¶1} Following a bench trial, defendant-appellant Natalie Ridley was convicted of patient abuse under R.C. 2903.34(A)(1). She presents three assignments of error.”
State v. Webb, 2025-Ohio-456. “34 provides, in relevant part: (A) No person who owns, operates, or administers, or who is an agent or employee of, a care facility shall do any of the following: (1) Commit abuse against a resident or patient of the facility.”
State v. Caraballo, 2012-Ohio-5725. “: {¶1} Defendant-appellant Virgen Caraballo appeals from her convictions and the consecutive sentences imposed after she pleaded guilty in the Cuyahoga County Court of Common Pleas to seven counts of patient abuse in violation of R.C. 2903.34(A)(1). {¶2} Caraballo presents five…”
State v. Buell, 2016-Ohio-5477.
State v. Evans, 2014-Ohio-2081. “Facts and Procedural History {¶ 2} On November 5, 2012, appellee filed an application requesting the trial court seal the record of her conviction for attempted patient abuse in violation of R.C. 2903.34, a first-degree misdemeanor.”
Ohio Rev. Code § 2903.34(A)(2): 5 cases
State v. Hustead, 615 N.E.2d 1081 (Ohio Ct. App. 4th Dist. 1992). “This is an appeal from a jury verdict of the Ross County Court of Common Pleas which found Kathleen Hustead guilty of violating R.C. 2903.34, patient abuse. Hustead worked in a nursing home.”
State v. Curry, 601 N.E.2d 176 (Ohio Ct. App. 8th Dist. 1991). “I On August 29,1989, defendant, an employee of Warrensville Developmental Center, was indicted for one count of patient abuse, in violation of R.C. 2903.34. Defendant pleaded not guilty and the matter proceeded to a bench trial on December 11, 1989.”
State v. Hahaj, 2025-Ohio-52, 260 N.E.3d 1150.
State v. Goins, 2022-Ohio-985, 187 N.E.3d 42.
State ex rel. Woznak v. Cuyahoga Cty. Prosecutor's Off., 2026-Ohio-2191.
Ohio Rev. Code § 2903.34(A)(3): 3 cases
State v. Goins, 2022-Ohio-985, 187 N.E.3d 42.
State v. Williams, 599 N.E.2d 377 (Ohio Ct. App. 8th Dist. 1991).
Toledo v. Spiess, 2023-Ohio-1099.
Ohio Rev. Code § 2903.34(D): 1 case
State ex rel. Woznak v. Cuyahoga Cty. Prosecutor's Off., 2026-Ohio-2191.
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