Ohio Rev. Code » Chapter 2905
Ohio Revised Code

Ohio Rev. Code § 2905.03 (2026)

Unlawful restraint

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Effective:
January 1, 2008
Latest Legislation:
Senate Bill 10 - 127th General Assembly
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(A) No person, without privilege to do so, shall knowingly restrain another of the other person's liberty.

(B) No person, without privilege to do so and with a sexual motivation, shall knowingly restrain another of the other person's liberty.

(C) Whoever violates this section is guilty of unlawful restraint, a misdemeanor of the third 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 78 cases (19 in the last 5 years), 1959–2026 · leading case: State v. Mole (Slip Opinion), 2016-Ohio-5124, 74 N.E.3d 368.
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State v. Mole (Slip Opinion), 2016-Ohio-5124, 74 N.E.3d 368. · cites it 5× “1) (prohibiting sexual 3 Former R.C. 2905.03 provided: “No person eighteen years of age or over shall carnally know and abuse a female person under the age of sixteen years with her consent.”
Jacobson v. Kaforey (Slip Opinion), 2016-Ohio-8434, 75 N.E.3d 203. · cites it 2× “Each of those claims sought recovery for damages arising out of the alleged violation of a criminal statute: unlawful restraint, R.C. 2905.03; kidnapping, R.C. 2905.01; and child enticement, R.”
State v. Alghamdi, 2018-Ohio-3158. · cites it 6× “IN THE ALTERNATIVE, THE JURY LOST ITS WAY IN FINDING THE APPELLANT GUILTY OF UNLAWFUL RESTRAINT, IN VIOLATION OF R.C. 2905.03. {¶4} Mr. Alghamdi argues that the State failed to prove that he committed the offense of unlawful restraint.”
State v. Cornwell, 2015-Ohio-4617, 48 N.E.3d 169. · cites it 4× “Unlawful Restraint {¶22} R.C. 2905.03, Ohio’s unlawful restraint statute, provides that “[n]o person, without privilege to do so, shall knowingly restrain another of the other person's liberty.”
State v. Curry, 330 N.E.2d 720 (Ohio 1975). · cites it 2× “2d 736 , this court held: “Consent of the victim is not an essential element of the crime of statutory rape specified in Section 2905.03, Revised Code * * Hence, there are three elements to the crime of statutory rape: (1) the defendant must have been 18 years of age or older at…”
State v. Williams, 599 N.E.2d 377 (Ohio Ct. App. 8th Dist. 1991). · cites it 7× “34(A)(3), and one count of unlawful restraint, in violation of R.C. 2905.03. A codefendant, Idelia Trapp, was charged with the same offenses.”
United States v. Gonzalez-Ramirez, 477 F.3d 310 (5th Cir. 2007). “460 (2005) (elevating the offense to a felony under certain circumstances, including when a deadly weapon is used); Ohio Rev.Code Ann. § 2905.03 (West 1997); Tex.”
Cleveland v. Watson, 2020-Ohio-3284. · cites it 2× “08(a) is nearly identical to unlawful restraint under R.C. 2905.03(A). This court has held that to convict someone of unlawful restraint under R.”
State v. Burnette, 2022-Ohio-1103. · cites it 2× “Finally, a person engages in disorderly conduct if he “recklessly cause[s] inconvenience, annoyance, or alarm to another by * * * [e]ngaging in fighting, in threatening harm to persons or property, or in violent or turbulent behavior[.”
City of East Cleveland v. Odetellah, 633 N.E.2d 1159 (Ohio Ct. App. 8th Dist. 1993). · cites it 3× “See, also, R.C. 2905.03. R.C. 2901.01(L) provides that: *791 “ ‘Privilege’ means an immunity, license, or right conferred by law, or bestowed by express or implied grant, or arising out of status, position, office, or relationship, or growing out of necessity.”
State v. Graves, 2015-Ohio-3936. “-6- Clermont CA2015-03-022 {¶ 21} Graves was also convicted of trafficking in heroin and aggravated trafficking in drugs in violation of R.C. 2905.03(A)(2), which provides, "[n]o person shall knowingly * * * [p]repare for shipment * * * prepare for distribution, or distribute a…”
State v. Sheeders, 2019-Ohio-3120. · cites it 2× “*** R.C. 2905.03. The definition of “knowingly” is the same as for aggravated menacing under R.”
Show all 78 citing cases →
Ohio Rev. Code § 2905.03(A): 35 cases
State v. Alghamdi, 2018-Ohio-3158. “IN THE ALTERNATIVE, THE JURY LOST ITS WAY IN FINDING THE APPELLANT GUILTY OF UNLAWFUL RESTRAINT, IN VIOLATION OF R.C. 2905.03. {¶4} Mr. Alghamdi argues that the State failed to prove that he committed the offense of unlawful restraint.”
State v. Cornwell, 2015-Ohio-4617, 48 N.E.3d 169. “Unlawful Restraint {¶22} R.C. 2905.03, Ohio’s unlawful restraint statute, provides that “[n]o person, without privilege to do so, shall knowingly restrain another of the other person's liberty.”
Cleveland v. Watson, 2020-Ohio-3284. “08(a) is nearly identical to unlawful restraint under R.C. 2905.03(A). This court has held that to convict someone of unlawful restraint under R.”
State v. Burnette, 2022-Ohio-1103. “Finally, a person engages in disorderly conduct if he “recklessly cause[s] inconvenience, annoyance, or alarm to another by * * * [e]ngaging in fighting, in threatening harm to persons or property, or in violent or turbulent behavior[.”
State v. Oliver, 2018-Ohio-3667, 112 N.E.3d 573.
Ohio Rev. Code § 2905.03(A)(1): 1 case
State v. Rutledge, 2025-Ohio-4573.
Ohio Rev. Code § 2905.03(A)(2): 1 case
State v. Graves, 2015-Ohio-3936. “-6- Clermont CA2015-03-022 {¶ 21} Graves was also convicted of trafficking in heroin and aggravated trafficking in drugs in violation of R.C. 2905.03(A)(2), which provides, "[n]o person shall knowingly * * * [p]repare for shipment * * * prepare for distribution, or distribute a…”
Ohio Rev. Code § 2905.03(A)(4): 1 case
State v. Shilbaya, 2018-Ohio-1991.
Ohio Rev. Code § 2905.03(A)(5): 2 cases
State v. Volpi, 2023-Ohio-4488, 231 N.E.3d 654.
State v. Chandler, 813 N.E.2d 65 (Ohio Ct. App. 5th Dist. 2004).
Ohio Rev. Code § 2905.03(B): 4 cases
State v. Adhikari, 2017-Ohio-460, 84 N.E.3d 282.
State v. Singh, 2015-Ohio-4130.
Mohammad v. Shahwan, 2023-Ohio-4811.
State v. Browning, 2025-Ohio-2989.
Ohio Rev. Code § 2905.03(C): 2 cases
State v. Boyce, 2024-Ohio-464.
State v. Singh, 2015-Ohio-4130.
Ohio Rev. Code § 2905.03(C)(1)(d): 1 case
State v. Douglass, 2020-Ohio-1214.
Ohio Rev. Code § 2905.03(C)(3)(a): 1 case
State v. Ayers, 2012-Ohio-3175.
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