Ohio Revised Code

Ohio Rev. Code § 2921.33 (2026)

Resisting arrest

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(A) No person, recklessly or by force, shall resist or interfere with a lawful arrest of the person or another.

(B) No person, recklessly or by force, shall resist or interfere with a lawful arrest of the person or another person and, during the course of or as a result of the resistance or interference, cause physical harm to a law enforcement officer.

(C) No person, recklessly or by force, shall resist or interfere with a lawful arrest of the person or another person if either of the following applies:

(1) The offender, during the course of or as a result of the resistance or interference, recklessly causes physical harm to a law enforcement officer by means of a deadly weapon;

(2) The offender, during the course of the resistance or interference, brandishes a deadly weapon.

(D) Whoever violates this section is guilty of resisting arrest. A violation of division (A) of this section is a misdemeanor of the second degree. A violation of division (B) of this section is a misdemeanor of the first degree. A violation of division (C) of this section is a felony of the fourth degree.

(E) As used in this section, "deadly weapon" has the same meaning as in section 2923.11 of the Revised Code.

Notes of Decisions
Cited in 393 cases (152 in the last 5 years), 1981–2026 · leading case: City of Akron v. Callaway, 835 N.E.2d 736 (Ohio Ct. App. 9th Dist. 2005).
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City of Akron v. Callaway, 835 N.E.2d 736 (Ohio Ct. App. 9th Dist. 2005). · cites it 15× “13 [resisting arrest], as it conflicts with R.C. § 2921.33 in permitting convictions where the arrest was not proven to be lawful.”
State v. McCrone, 580 N.E.2d 468 (Ohio Ct. App. 9th Dist. 1989). · cites it 10× “Assignment of Error 2 “The trial court erred in failing to grant defendant’s motion for judgment of acquittal on the charge of resisting arrest (O.R.C. 2921.33) at the conclusion of all evidence.”
State v. Harvey, 2020-Ohio-329. · cites it 4× “{¶7} On November 20, 2018, Harvey was charged with one count of resisting arrest in violation of R.C. 2921.33(A); one count of obstructing official business in violation of R.”
State v. Madding, 2011-Ohio-3865. · cites it 21× “Neither the name nor the identity of the offense of resisting arrest in violation of R.C. 2921.33 was changed when the Revised Code designation in the complaint was amended.”
State v. Johnson, 453 N.E.2d 1101 (Ohio Ct. App. 12th Dist. 1982). · cites it 7× “That court, at page 256, noted the appropriate standard for a “lawful arrest,” to wit: “* * * If the facts surrounding Ms.”
State v. Terry, 2016-Ohio-3484. · cites it 4× “31, and without this charge there can be no validity to the charge of resisting arrest, R.C. 2921.33.” Terry’s first argument here focuses on the sufficiency of the evidence supporting the conviction for obstructing official business.”
State v. Armstrong-Carter, 2021-Ohio-1110. · cites it 6× “* * * “ ‘ [T]he absence of excessive or unnecessary force is not a material element of the crime of resisting arrest as defined in R.C. 2921.33.’ ” [Blanchester v. Newland, 12th Dist.”
City of Elyria v. Tress, 595 N.E.2d 1031 (Ohio Ct. App. 9th Dist. 1991). · cites it 6× “19(A)(1), and resisting arrest, R.C. 2921.33(A). Shortly after 11:00 p.m.”
Lamar Wright v. City of Euclid, 962 F.3d 852 (6th Cir. 2020). “2018); see Ohio Rev. Code § 2921.33(A) (“No person, recklessly or by force, shall resist or interfere with a lawful arrest .”
State v. Fussell, 2011-Ohio-4815. · cites it 10× “Because there is insufficient evidence establishing that Fussell caused Officer Telegdy’s injury, we must address Fussell’s conviction for resisting arrest in violation of R.”
State v. Pierce, 2017-Ohio-4223. · cites it 3× “31(A) and resisting arrest in violation of R.C. 2921.33(A). Doc. 1, 2. The jury trial was set for November 2, 2016.”
Mansfield v. Studer, 2012-Ohio-4840. · cites it 3× “2011-CA-93 & 2011-CA-94 29 {¶89} With regard to the resisting arrest charge, the elements are set forth in R.C. 2921.33, which provides in pertinent part, “(A) No person, recklessly or by force, shall resist or interfere with a lawful arrest of the person or another.”
Show all 393 citing cases →
Ohio Rev. Code § 2921.33(A): 226 cases
State v. Harvey, 2020-Ohio-329. “{¶7} On November 20, 2018, Harvey was charged with one count of resisting arrest in violation of R.C. 2921.33(A); one count of obstructing official business in violation of R.”
State v. McCrone, 580 N.E.2d 468 (Ohio Ct. App. 9th Dist. 1989). “Assignment of Error 2 “The trial court erred in failing to grant defendant’s motion for judgment of acquittal on the charge of resisting arrest (O.R.C. 2921.33) at the conclusion of all evidence.”
City of Elyria v. Tress, 595 N.E.2d 1031 (Ohio Ct. App. 9th Dist. 1991). “19(A)(1), and resisting arrest, R.C. 2921.33(A). Shortly after 11:00 p.m.”
Lamar Wright v. City of Euclid, 962 F.3d 852 (6th Cir. 2020). “2018); see Ohio Rev. Code § 2921.33(A) (“No person, recklessly or by force, shall resist or interfere with a lawful arrest .”
State v. Armstrong-Carter, 2021-Ohio-1110. “* * * “ ‘ [T]he absence of excessive or unnecessary force is not a material element of the crime of resisting arrest as defined in R.C. 2921.33.’ ” [Blanchester v. Newland, 12th Dist.”
Ohio Rev. Code § 2921.33(A)(1): 2 cases
State v. Ewing, 2017-Ohio-7194, 95 N.E.3d 1112.
State v. Madding, 2011-Ohio-3865. “Neither the name nor the identity of the offense of resisting arrest in violation of R.C. 2921.33 was changed when the Revised Code designation in the complaint was amended.”
Ohio Rev. Code § 2921.33(A)(D): 3 cases
State v. Ahmad, 2018-Ohio-3556.
State v. Ahmad, 2017-Ohio-6991.
State v. Ahmad, 2021-Ohio-1418.
Ohio Rev. Code § 2921.33(B): 53 cases
State v. Madding, 2011-Ohio-3865. “Neither the name nor the identity of the offense of resisting arrest in violation of R.C. 2921.33 was changed when the Revised Code designation in the complaint was amended.”
State v. Pitts, 2022-Ohio-4172, 201 N.E.3d 983.
State v. Fussell, 2011-Ohio-4815. “Because there is insufficient evidence establishing that Fussell caused Officer Telegdy’s injury, we must address Fussell’s conviction for resisting arrest in violation of R.”
State v. Buckley, 2019-Ohio-3991.
State v. Devaughn, 2020-Ohio-651.
Ohio Rev. Code § 2921.33(B)(C): 1 case
State v. Blanton, 2025-Ohio-237, 261 N.E.3d 604.
Ohio Rev. Code § 2921.33(B)(D): 2 cases
State v. Hill, 2014-Ohio-919.
State v. Sisson, 2023-Ohio-1273.
Ohio Rev. Code § 2921.33(B)(c)(5)(a): 1 case
Cooper v. Youngstown, 2016-Ohio-7184.
Ohio Rev. Code § 2921.33(C): 3 cases
State v. Simms, 844 N.E.2d 1212 (Ohio Ct. App. 4th Dist. 2005).
State v. Holladay, 2020-Ohio-5459.
Damato v. Kasimer, No. 1:18-cv-00680 (N.D. Ohio Mar. 20, 2020).
Ohio Rev. Code § 2921.33(C)(1): 6 cases
State v. Stevens, 2020-Ohio-6981.
State v. Holladay, 2020-Ohio-5459.
State v. Stevens, 2022-Ohio-3781.
State v. Schmidt, 2019-Ohio-3990.
State v. Latimore, 2011-Ohio-3562.
Ohio Rev. Code § 2921.33(C)(2): 7 cases
Render v. Warden, S. Ohio Corr. Facility, 889 F. Supp. 2d 1014 (S.D. Ohio 2012).
State v. Dean, 2018-Ohio-1317, 110 N.E.3d 739.
State v. Watson, 2025-Ohio-515.
State v. Miller, 2024-Ohio-913.
State v. Ackert, 2024-Ohio-5676.
Ohio Rev. Code § 2921.33(C)(5)(a)(ii): 2 cases
State v. Austin, 2019-Ohio-686.
State v. Carter, 2019-Ohio-3443.
Ohio Rev. Code § 2921.33(D): 6 cases
State v. Brauchler, 2020-Ohio-2731.
State v. Swift, 2023-Ohio-1435.
Akron v. Ragsdale, 2025-Ohio-1048.
State v. Kornilov, 2012-Ohio-6218.
State v. Norris, 2020-Ohio-764.
Ohio Rev. Code § 2921.33(E): 1 case
State v. Austin, 2019-Ohio-686.
Ohio Rev. Code § 2921.33(O): 1 case
State v. Larrick, 2023-Ohio-4663.
Ohio Rev. Code § 2921.33(a): 2 cases
Hicks v. City of Akron, No. 5:23-cv-00001 (N.D. Ohio Feb. 22, 2024).
Spencer v. Cleveland Clinic Found., No. 1:21-cv-01909, 2022 WL 2954175 (N.D. Ohio July 26, 2022).
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