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Ohio Revised Code

Ohio Rev. Code § 2905.03 (2026)

Unlawful restraint

✓ current as of May 2026
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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 (Ohio 2016).
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State v. Mole (Slip Opinion), 2016 Ohio 5124 (Ohio 2016). · 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 (Ohio 2016). · 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 (Ohio Ct. App. 2018). · 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 (Ohio Ct. App. 2015). · 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. 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 (Ohio Ct. App. 2020). · 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 (Ohio Ct. App. 2022). · 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. 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 (Ohio Ct. App. 2015). “-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 (Ohio Ct. App. 2019). · 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 (Ohio Ct. App. 2018). “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 (Ohio Ct. App. 2015). “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 (Ohio Ct. App. 2020). “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 (Ohio Ct. App. 2022). “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 (Ohio Ct. App. 2018).
— Ohio Rev. Code § 2905.03(A)(1) — 1 case
State v. Rutledge, 2025 Ohio 4573 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2905.03(A)(2) — 1 case
State v. Graves, 2015 Ohio 3936 (Ohio Ct. App. 2015). “-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 Ct. App. 2018).
— Ohio Rev. Code § 2905.03(A)(5) — 2 cases
State v. Volpi, 2023 Ohio 4488 (Ohio Ct. App. 2023).
State v. Chandler, 813 N.E.2d 65 (Ohio Ct. App. 2004).
— Ohio Rev. Code § 2905.03(B) — 4 cases
State v. Adhikari, 2017 Ohio 460 (Ohio Ct. App. 2017).
State v. Singh, 2015 Ohio 4130 (Ohio Ct. App. 2015).
Mohammad v. Shahwan, 2023 Ohio 4811 (Ohio Ct. App. 2023).
State v. Browning, 2025 Ohio 2989 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2905.03(C) — 2 cases
State v. Boyce, 2024 Ohio 464 (Ohio Ct. App. 2024).
State v. Singh, 2015 Ohio 4130 (Ohio Ct. App. 2015).
— Ohio Rev. Code § 2905.03(C)(1)(d) — 1 case
State v. Douglass, 2020 Ohio 1214 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2905.03(C)(3)(a) — 1 case
State v. Ayers, 2012 Ohio 3175 (Ohio Ct. App. 2012).
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