Ohio Rev. Code » Chapter 2921
Ohio Revised Code

Ohio Rev. Code § 2921.32 (2026)

Obstructing justice

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Effective:
June 27, 2012
Latest Legislation:
House Bill 262 - 129th General Assembly
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(A) No person, with purpose to hinder the discovery, apprehension, prosecution, conviction, or punishment of another for crime or to assist another to benefit from the commission of a crime, and no person, with purpose to hinder the discovery, apprehension, prosecution, adjudication as a delinquent child, or disposition of a child for an act that if committed by an adult would be a crime or to assist a child to benefit from the commission of an act that if committed by an adult would be a crime, shall do any of the following:

(1) Harbor or conceal the other person or child;

(2) Provide the other person or child with money, transportation, a weapon, a disguise, or other means of avoiding discovery or apprehension;

(3) Warn the other person or child of impending discovery or apprehension;

(4) Destroy or conceal physical evidence of the crime or act, or induce any person to withhold testimony or information or to elude legal process summoning the person to testify or supply evidence;

(5) Communicate false information to any person;

(6) Prevent or obstruct any person, by means of force, intimidation, or deception, from performing any act to aid in the discovery, apprehension, or prosecution of the other person or child.

(B) A person may be prosecuted for, and may be convicted of or adjudicated a delinquent child for committing, a violation of division (A) of this section regardless of whether the person or child aided ultimately is apprehended for, is charged with, is convicted of, pleads guilty to, or is adjudicated a delinquent child for committing the crime or act the person or child aided committed. The crime or act the person or child aided committed shall be used under division (C) of this section in determining the penalty for the violation of division (A) of this section, regardless of whether the person or child aided ultimately is apprehended for, is charged with, is convicted of, pleads guilty to, or is adjudicated a delinquent child for committing the crime or act the person or child aided committed.

(C)(1) Whoever violates this section is guilty of obstructing justice.

(2) If the crime committed by the person aided is a misdemeanor or if the act committed by the child aided would be a misdemeanor if committed by an adult, obstructing justice is a misdemeanor of the same degree as the crime committed by the person aided or a misdemeanor of the same degree that the act committed by the child aided would be if committed by an adult.

(3) Except as otherwise provided in divisions (C)(4), (5), and (6) of this section, if the crime committed by the person aided is a felony or if the act committed by the child aided would be a felony if committed by an adult, obstructing justice is a felony of the fifth degree.

(4) Except as otherwise provided in division (C)(6) of this section, if the crime committed by the person aided is aggravated murder, murder, or a felony of the first or second degree or if the act committed by the child aided would be one of those offenses if committed by an adult and if the offender knows or has reason to believe that the crime committed by the person aided is one of those offenses or that the act committed by the child aided would be one of those offenses if committed by an adult, obstructing justice is a felony of the third degree.

(5) If the crime or act committed by the person or child aided is an act of terrorism, obstructing justice is one of the following:

(a) Except as provided in division (C)(5)(b) of this section, a felony of the second degree;

(b) If the act of terrorism resulted in the death of a person who was not a participant in the act of terrorism, a felony of the first degree.

(6) If the crime committed by the person is trafficking in persons or if the act committed by the child aided would be trafficking in persons if committed by an adult, obstructing justice is a felony of the second degree.

(D) As used in this section:

(1) "Adult" and "child" have the same meanings as in section 2151.011 of the Revised Code.

(2) "Delinquent child" has the same meaning as in section 2152.02 of the Revised Code.

(3) "Act of terrorism" has the same meaning as in section 2909.21 of the Revised Code.
Notes of Decisions
Cited in 199 cases (60 in the last 5 years), 1978–2026 · leading case: State v. Blanton, 2015-Ohio-4620, 48 N.E.3d 1018.
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State v. Blanton, 2015-Ohio-4620, 48 N.E.3d 1018. · cites it 12× “Noticeably, any requirement that a defendant’s conduct hinder the police is absent from the statutory language of R.C. 2921.32. Contrast this statute with R.”
State v. Howard, 600 N.E.2d 809 (Ohio Ct. App. 4th Dist. 1991). · cites it 10× “The court held that while mere unsworn oral misstatements in response to inquiries by police officers do not violate R.C. 2921.32(A), the defendant's attempt to block the view of the police officer and prevent the officer from entering the house, and the defendant’s attempt to…”
State v. Baker, 739 N.E.2d 819 (Ohio Ct. App. 12th Dist. 2000). · cites it 8× “Baker, appeals his convictions in the Clinton County Court of Common Pleas for obstructing justice in violation of R.C. 2921.32(A) and tampering with evidence in violation of R.”
State v. Heckathorn, 2019-Ohio-1086, 17 CO 11. · cites it 6× “C-810539 (May 12, 1982) (complaint fails to state a violation of R.C. 2921.32 where the alleged purpose was to hinder the discovery of himself, rather than someone else).”
State v. Gordon, 458 N.E.2d 1277 (Ohio Ct. App. 1st Dist. 1983). · cites it 8× “31 1 is a lesser included offense of the crime of obstructing justice in violation of R.C. 2921.32 2 ; and whether the evidence was sufficient to prove that appellant’s acts amounted to hampering or impeding police officers in the performance of their duty, in violation of R.”
Shoup v. Doyle, 974 F. Supp. 2d 1058 (S.D. Ohio 2013). · cites it 4× “31, which prohibits the obstruction of official business, or Ohio Rev.Code § 2921.32, which prohibits the obstruction of justice.”
State v. Bailey, 644 N.E.2d 314 (Ohio 1994). · cites it 6× “The issue presented is whether the making of unsworn false oral statements to a law enforcement officer with the purpose to hinder the officer’s investigation of a crime constitutes conduct punishable within the meaning of R.C. 2921.32(A)(5). We conclude that such statements are…”
State v. Conway, 848 N.E.2d 810 (Ohio 2006). “01(B); Count Five, obstruction of justice, R.C. 2921.32(A)(4) and (C)(4); and Count Six, tampering with evidence, R.”
State v. Dixon, 2022-Ohio-2807. · cites it 4× “{¶5} On September 25, 2020, a Hocking County Grand Jury returned an indictment that charged appellant with (1) obstructing justice in violation of R.C. 2921.32(A)(5)/(C)(4), a third-degree felony, and (2) obstructing justice in violation of R.”
State v. Yarbrough, 767 N.E.2d 216 (Ohio 2002). “The statement could be construed as implying that he permitted the others to wash off the blood, which could be deemed to violate R.C. 2921.32(A), obstructing justice. {¶ 63} However, the rule requires that the statement so far subjected him to criminal liability that a…”
State v. Yarbrough, 2002-Ohio-2126, 767 N.E.2d 216. “The statement could be construed as implying that he permitted the others to wash off the blood, which could be deemed to violate R.C. 2921.32(A), obstructing justice. {¶63} However, the rule requires that the statement so far subjected him to criminal liability that a…”
State v. Evans, 2012-Ohio-1562. · cites it 4× “Falsification and Obstructing Justice {¶80} We find that Count Thirteen (falsification), Count Fourteen (obstructing justice under R.C. 2921.32(A)(2)), and Count Fifteen (obstructing justice under R.”
Show all 199 citing cases →
Ohio Rev. Code § 2921.32(1): 1 case
State v. Green, 921 N.E.2d 276 (Ohio Ct. App. 4th Dist. 2009).
Ohio Rev. Code § 2921.32(A): 15 cases
State v. Yarbrough, 767 N.E.2d 216 (Ohio 2002). “The statement could be construed as implying that he permitted the others to wash off the blood, which could be deemed to violate R.C. 2921.32(A), obstructing justice. {¶ 63} However, the rule requires that the statement so far subjected him to criminal liability that a…”
State v. Yarbrough, 2002-Ohio-2126, 767 N.E.2d 216. “The statement could be construed as implying that he permitted the others to wash off the blood, which could be deemed to violate R.C. 2921.32(A), obstructing justice. {¶63} However, the rule requires that the statement so far subjected him to criminal liability that a…”
State v. Baker, 739 N.E.2d 819 (Ohio Ct. App. 12th Dist. 2000). “Baker, appeals his convictions in the Clinton County Court of Common Pleas for obstructing justice in violation of R.C. 2921.32(A) and tampering with evidence in violation of R.”
Parra v. Jackson, 2021-Ohio-1188, 171 N.E.3d 452.
State v. Howard, 600 N.E.2d 809 (Ohio Ct. App. 4th Dist. 1991). “The court held that while mere unsworn oral misstatements in response to inquiries by police officers do not violate R.C. 2921.32(A), the defendant's attempt to block the view of the police officer and prevent the officer from entering the house, and the defendant’s attempt to…”
Ohio Rev. Code § 2921.32(A)(1): 17 cases
State v. Howard, 600 N.E.2d 809 (Ohio Ct. App. 4th Dist. 1991). “The court held that while mere unsworn oral misstatements in response to inquiries by police officers do not violate R.C. 2921.32(A), the defendant's attempt to block the view of the police officer and prevent the officer from entering the house, and the defendant’s attempt to…”
State v. Blanton, 2015-Ohio-4620, 48 N.E.3d 1018. “Noticeably, any requirement that a defendant’s conduct hinder the police is absent from the statutory language of R.C. 2921.32. Contrast this statute with R.”
State v. Gordon, 458 N.E.2d 1277 (Ohio Ct. App. 1st Dist. 1983). “31 1 is a lesser included offense of the crime of obstructing justice in violation of R.C. 2921.32 2 ; and whether the evidence was sufficient to prove that appellant’s acts amounted to hampering or impeding police officers in the performance of their duty, in violation of R.”
State v. Green, 921 N.E.2d 276 (Ohio Ct. App. 4th Dist. 2009).
State v. Byrd, 2017-Ohio-6903.
Ohio Rev. Code § 2921.32(A)(2): 11 cases
State v. Baker, 739 N.E.2d 819 (Ohio Ct. App. 12th Dist. 2000). “Baker, appeals his convictions in the Clinton County Court of Common Pleas for obstructing justice in violation of R.C. 2921.32(A) and tampering with evidence in violation of R.”
State v. Evans, 2012-Ohio-1562. “Falsification and Obstructing Justice {¶80} We find that Count Thirteen (falsification), Count Fourteen (obstructing justice under R.C. 2921.32(A)(2)), and Count Fifteen (obstructing justice under R.”
State v. Forney, 2013-Ohio-3458.
State v. Naugle, 913 N.E.2d 1052 (Ohio Ct. App. 5th Dist. 2009).
State v. Ernest, 2015-Ohio-2983.
Ohio Rev. Code § 2921.32(A)(2)(4)(5): 1 case
State v. Sloan, 2022-Ohio-1930.
Ohio Rev. Code § 2921.32(A)(3): 1 case
State v. Carroll, 2024-Ohio-628.
Ohio Rev. Code § 2921.32(A)(4): 22 cases
State v. Conway, 848 N.E.2d 810 (Ohio 2006). “01(B); Count Five, obstruction of justice, R.C. 2921.32(A)(4) and (C)(4); and Count Six, tampering with evidence, R.”
State v. Baker, 739 N.E.2d 819 (Ohio Ct. App. 12th Dist. 2000). “Baker, appeals his convictions in the Clinton County Court of Common Pleas for obstructing justice in violation of R.C. 2921.32(A) and tampering with evidence in violation of R.”
Evans v. Dept. of Rehab. & Corr., 2019-Ohio-3788.
State v. McIntyre, 2016-Ohio-93.
State v. Betts, 2020-Ohio-4800.
Ohio Rev. Code § 2921.32(A)(4)(5): 1 case
State v. Burns, 2019-Ohio-1141.
Ohio Rev. Code § 2921.32(A)(4)(C)(4): 1 case
State v. Simmons, 2020-Ohio-6813.
Ohio Rev. Code § 2921.32(A)(5): 64 cases
State v. Heckathorn, 2019-Ohio-1086, 17 CO 11. “C-810539 (May 12, 1982) (complaint fails to state a violation of R.C. 2921.32 where the alleged purpose was to hinder the discovery of himself, rather than someone else).”
State v. Bailey, 644 N.E.2d 314 (Ohio 1994). “The issue presented is whether the making of unsworn false oral statements to a law enforcement officer with the purpose to hinder the officer’s investigation of a crime constitutes conduct punishable within the meaning of R.C. 2921.32(A)(5). We conclude that such statements are…”
State v. Dixon, 2022-Ohio-2807. “{¶5} On September 25, 2020, a Hocking County Grand Jury returned an indictment that charged appellant with (1) obstructing justice in violation of R.C. 2921.32(A)(5)/(C)(4), a third-degree felony, and (2) obstructing justice in violation of R.”
State v. Lazzaro, 667 N.E.2d 384 (Ohio 1996).
State v. Smith, 2012-Ohio-794.
Ohio Rev. Code § 2921.32(A)(5)(C)(4): 3 cases
State v. Fletcher, 2018-Ohio-3726.
State v. Paige, 2018-Ohio-2782.
State v. Simmons, 2020-Ohio-6813.
Ohio Rev. Code § 2921.32(A)(6): 8 cases
State v. McKinney, 2019-Ohio-1118.
State v. Fussell, 2011-Ohio-4815.
State v. McIntyre, 2016-Ohio-93.
State v. Toney, 2011-Ohio-2464.
State v. Stanifer, 2017-Ohio-2721.
Ohio Rev. Code § 2921.32(A)(C)(2): 1 case
State v. Benson, 2019-Ohio-4635.
Ohio Rev. Code § 2921.32(AX5): 1 case
State v. Bolyard, 587 N.E.2d 380 (Ohio Ct. App. 9th Dist. 1990).
Ohio Rev. Code § 2921.32(B): 2 cases
State v. Connor, 612 N.E.2d 421 (Ohio Ct. App. 9th Dist. 1992).
Roberson v. Mohr, 596 N.E.2d 1112 (Ohio Ct. App. 4th Dist. 1991).
Ohio Rev. Code § 2921.32(C)(1): 1 case
State v. Betts, 2020-Ohio-4800.
Ohio Rev. Code § 2921.32(C)(2): 1 case
State v. Carroll, 2024-Ohio-628.
Ohio Rev. Code § 2921.32(C)(3): 2 cases
State v. Wilson, 2022-Ohio-1146.
State v. Carroll, 2024-Ohio-628.
Ohio Rev. Code § 2921.32(C)(4): 3 cases
State v. Grabe, 2020-Ohio-4435.
State v. Moore, 2020-Ohio-3708.
State v. Shaw, 2016-Ohio-7699.
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