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Ohio Revised Code

Ohio Rev. Code § 2933.32 (2026)

Body cavity search, strip search - conducting unauthorized search - failure to prepare proper search report

✓ current as of May 2026
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Effective:
September 30, 2025
Latest Legislation:
House Bill 96 - 136th General Assembly
PDF:
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(A) As used in this section:

(1) "Body cavity search" means an inspection of the anal or vaginal cavity of a person that is conducted visually, manually, by means of any instrument, apparatus, or object, or in any other manner.

(2) "Medical practitioner" has the same meaning as in section 4743.10 of the Revised Code.

(3) "Strip search" means an inspection of the genitalia, buttocks, breasts, or undergarments of a person that is preceded by the removal or rearrangement of some or all of the person's clothing that directly covers the person's genitalia, buttocks, breasts, or undergarments and that is conducted visually, manually, by means of any instrument, apparatus, or object, or in any other manner while the person is detained or arrested for the alleged commission of a misdemeanor or traffic offense. "Strip search" does not mean the visual observation of a person who was afforded a reasonable opportunity to secure release on bail or recognizance, who fails to secure such release, and who is to be integrated with the general population of any detention facility, while the person is changing into clothing that is required to be worn by inmates in the facility.

(B)(1) Except as authorized by this division, no law enforcement officer, other employee of a law enforcement agency, physician, or registered nurse or licensed practical nurse shall conduct or cause to be conducted a body cavity search or a strip search.

(2) A body cavity search or strip search may be conducted if a law enforcement officer or employee of a law enforcement agency has probable cause to believe that the person is concealing evidence of the commission of a criminal offense, including fruits or tools of a crime, contraband, or a deadly weapon, as defined in section 2923.11 of the Revised Code, that could not otherwise be discovered. In determining probable cause for purposes of this section, a law enforcement officer or employee of a law enforcement agency shall consider the nature of the offense with which the person to be searched is charged and the circumstances of the person's arrest.

(3) A body cavity search or strip search may be conducted for any legitimate medical or hygienic reason.

(4) Unless there is a legitimate medical reason or medical emergency justifying a warrantless search, a body cavity search shall be conducted only after a search warrant is issued that authorizes the search. In any case, a body cavity search shall be conducted under sanitary conditions and only by a physician, or a registered nurse or licensed practical nurse, who is registered or licensed to practice in this state.

(5) Unless there is a legitimate medical reason or medical emergency that makes obtaining written authorization impracticable, a body cavity search or strip search shall be conducted only after a law enforcement officer or employee of a law enforcement agency obtains a written authorization for the search from the person in command of the law enforcement agency, or from a person specifically designated by the person in command to give a written authorization for either type of search.

(6) A body cavity search or strip search shall be conducted by a person or persons who are of the same sex as the person who is being searched and the search shall be conducted in a manner and in a location that permits only the person or persons who are physically conducting the search and the person who is being searched to observe the search.

(C)(1) Upon completion of a body cavity search or strip search pursuant to this section, the person or persons who conducted the search shall prepare a written report concerning the search that shall include all of the following:

(a) The written authorization for the search obtained from the person in command of the law enforcement agency or that person's designee, if required by division (B)(5) of this section;

(b) The name of the person who was searched;

(c) The name of the person or persons who conducted the search, the time and date of the search, and the place at which the search was conducted;

(d) A list of the items, if any, recovered during the search;

(e) The facts upon which the law enforcement officer or employee of the law enforcement agency based the officer's or employee's probable cause for the search, including, but not limited to, the officer or employee's review of the nature of the offense with which the searched person is charged and the circumstances of the person's arrest;

(f) If the body cavity search was conducted before or without the issuance of a search warrant pursuant to division (B)(4) of this section, or if the body cavity or strip search was conducted before or without the granting of written authorization pursuant to division (B)(5) of this section, the legitimate medical reason or medical emergency that justified the warrantless search or made obtaining written authorization impracticable.

(2) A copy of the written report required by division (C)(1) of this section shall be kept on file in the law enforcement agency, and another copy of it shall be given to the person who was searched.

(D)(1) This section does not preclude the prosecution of a law enforcement officer or employee of a law enforcement agency for the violation of any other section of the Revised Code.

(2) This section does not limit, and shall not be construed to limit, any statutory or common law rights of a person to obtain injunctive relief or to recover damages in a civil action.

(3) If a person is subjected to a body cavity search or strip search in violation of this section, any person may commence a civil action to recover compensatory damages for any injury, death, or loss to person or property or any indignity arising from the violation. In the civil action, the court may award punitive damages to the plaintiffs if they prevail in the action, and it may award reasonable attorney's fees to the parties who prevail in the action.

(4) This section does not apply to body cavity searches or strip searches of persons who have been sentenced to serve a term of imprisonment and who are serving that term in a detention facility, as defined in section 2921.01 of the Revised Code.

(E)(1) Whoever violates division (B) of this section is guilty of conducting an unauthorized search, a misdemeanor of the first degree.

(2) Whoever violates division (C) of this section is guilty of failure to prepare a proper search report, a misdemeanor of the fourth degree.

(F) A medical practitioner is not required, and a court or other person shall not order a medical practitioner, to perform any medical procedure that is inconsistent with the medical practitioner's expert medical opinion.

Last updated August 4, 2025 at 3:46 PM

Notes of Decisions
Cited in 18 cases (1 in the last 5 years), 1985–2023 · leading case: State v. Mason, 2016 Ohio 7081 (Ohio Ct. App. 2016).
Sort: Relevance Newest Treatment
State v. Mason, 2016 Ohio 7081 (Ohio Ct. App. 2016). · cites it 2× “9 {¶25} Finally, Mason argues that the trial court improperly relied on R.C. 2933.32 in upholding the search of her person.”
Fann v. City of Cleveland, Ohio, 616 F. Supp. 305 (N.D. Ohio 1985). · cites it 6× “32(A)(2) provides this definition: "Strip search” means an inspection of the genitalia, buttocks, breasts, or undergarments of a person that is preceded by the removal or rearrangement of some or all of the person’s clothing that directly covers the person's genitalia, buttocks,…”
State v. Jones, 796 N.E.2d 989 (Ohio Ct. App. 2003). · cites it 7× “97API12-1587, 1998 WL 655277 , the Tenth District Court of Appeals stated: {¶ 33} “R.C. 2933.32 places express limitations on the manner in which strip searches are to be conducted.”
Deaton v. Burney, 669 N.E.2d 1 (Ohio Ct. App. 1995). · cites it 2× “In both their federal and state claims, the plaintiffs alleged that the strip searches were conducted in violation of R.C. 2933.32. In the federal action, the plaintiffs named the city of Dayton, Billy C.”
State v. Gonzales, 2014 Ohio 557 (Ohio Ct. App. 2014). “Specifically, Gonzales contends that there was no 6 With regard to this issue, the affidavit said specifically It is requested that the Search Warrant be granted for any persons found at the residence at the time the search warrant is executed pursuant to ORC 2933.32. Due to the…”
Disciplinary Couns. v. Ridenbaugh, 2009 Ohio 4091 (Ohio 2009). “{¶ 7} Respondent was indicted on three counts of intercepting wire, oral, or electronic communications in violation of R.C. 2933.32(A)(1), a felony of the fourth degree, and four counts of voyeurism in violation of R.”
Jones v. City of Brunswick, 704 F. Supp. 2d 721 (N.D. Ohio 2010). · cites it 2× “’” (citing O.R.C. 2933.32(A)(2))). 14 There can be no question, then, that misdemeanor arrestees have a reasonable expectation of privacy in their underwear-clad bodies.”
State v. Bush, 584 N.E.2d 1253 (Ohio Ct. App. 1989). · cites it 2× “32(B)(2) provides as follows: “A strip search may be conducted if a law enforcement officer * * * has probable cause to believe that the person is concealing evidence of the commission of a criminal offense * * * that could not otherwise be discovered.” In the case sub judice,…”
State v. McCullough, 2014 Ohio 1696 (Ohio Ct. App. 2014). “After reviewing the record, we question whether McCullough was subject to a "strip search" and "body cavity search" as those terms are defined by R.C. 2933.32(A)(1) and (2). This is particularly true given the fact that McCullough herself turned over the two baggies containing…”
Brown v. Short, 729 F. Supp. 2d 125 (D.D.C. 2010). “§ 2A:161A-3(a) (West 2009); Ohio Rev.Code Ann. § 2933.32(A)(2) (West 2009); Tenn.”
State v. Clark, 2016 Ohio 5493 (Ohio Ct. App. 2016). “" R.C. 2933.32(A)(1); R.C. 5120.421(A)(1). Black's Law Dictionary 4 She also testified that some unknown persons performed cavity searches on B.”
Washington v. Dep't of Rehab. & Corr., 166 Ohio App. 3d 797 (Ohio Ct. App. 2006). · cites it 7× “Appellant filed a complaint in the Court of Claims alleging a violation of Ohio’s statute governing strip searches, R.C. 2933.32, and a common-law claim for invasion of privacy.”
Show all 18 citing cases →
— Ohio Rev. Code § 2933.32(A)(1) — 6 cases
Disciplinary Couns. v. Ridenbaugh, 2009 Ohio 4091 (Ohio 2009). “{¶ 7} Respondent was indicted on three counts of intercepting wire, oral, or electronic communications in violation of R.C. 2933.32(A)(1), a felony of the fourth degree, and four counts of voyeurism in violation of R.”
State v. McCullough, 2014 Ohio 1696 (Ohio Ct. App. 2014). “After reviewing the record, we question whether McCullough was subject to a "strip search" and "body cavity search" as those terms are defined by R.C. 2933.32(A)(1) and (2). This is particularly true given the fact that McCullough herself turned over the two baggies containing…”
State v. Clark, 2016 Ohio 5493 (Ohio Ct. App. 2016). “" R.C. 2933.32(A)(1); R.C. 5120.421(A)(1). Black's Law Dictionary 4 She also testified that some unknown persons performed cavity searches on B.”
State v. Huggins, 2014 Ohio 4999 (Ohio Ct. App. 2014).
State v. Minor, 2016 Ohio 5492 (Ohio Ct. App. 2016).
— Ohio Rev. Code § 2933.32(A)(2) — 6 cases
Fann v. City of Cleveland, Ohio, 616 F. Supp. 305 (N.D. Ohio 1985). “32(A)(2) provides this definition: "Strip search” means an inspection of the genitalia, buttocks, breasts, or undergarments of a person that is preceded by the removal or rearrangement of some or all of the person’s clothing that directly covers the person's genitalia, buttocks,…”
Jones v. City of Brunswick, 704 F. Supp. 2d 721 (N.D. Ohio 2010). “’” (citing O.R.C. 2933.32(A)(2))). 14 There can be no question, then, that misdemeanor arrestees have a reasonable expectation of privacy in their underwear-clad bodies.”
Brown v. Short, 729 F. Supp. 2d 125 (D.D.C. 2010). “§ 2A:161A-3(a) (West 2009); Ohio Rev.Code Ann. § 2933.32(A)(2) (West 2009); Tenn.”
State v. Jones, 796 N.E.2d 989 (Ohio Ct. App. 2003). “97API12-1587, 1998 WL 655277 , the Tenth District Court of Appeals stated: {¶ 33} “R.C. 2933.32 places express limitations on the manner in which strip searches are to be conducted.”
State v. Huggins, 2014 Ohio 4999 (Ohio Ct. App. 2014).
— Ohio Rev. Code § 2933.32(B) — 3 cases
Fann v. City of Cleveland, Ohio, 616 F. Supp. 305 (N.D. Ohio 1985). “32(A)(2) provides this definition: "Strip search” means an inspection of the genitalia, buttocks, breasts, or undergarments of a person that is preceded by the removal or rearrangement of some or all of the person’s clothing that directly covers the person's genitalia, buttocks,…”
State v. Jones, 796 N.E.2d 989 (Ohio Ct. App. 2003). “97API12-1587, 1998 WL 655277 , the Tenth District Court of Appeals stated: {¶ 33} “R.C. 2933.32 places express limitations on the manner in which strip searches are to be conducted.”
Washington v. Dep't of Rehab. & Corr., 166 Ohio App. 3d 797 (Ohio Ct. App. 2006). “Appellant filed a complaint in the Court of Claims alleging a violation of Ohio’s statute governing strip searches, R.C. 2933.32, and a common-law claim for invasion of privacy.”
— Ohio Rev. Code § 2933.32(B)(2) — 4 cases
State v. Jones, 796 N.E.2d 989 (Ohio Ct. App. 2003). “97API12-1587, 1998 WL 655277 , the Tenth District Court of Appeals stated: {¶ 33} “R.C. 2933.32 places express limitations on the manner in which strip searches are to be conducted.”
State v. Bush, 584 N.E.2d 1253 (Ohio Ct. App. 1989). “32(B)(2) provides as follows: “A strip search may be conducted if a law enforcement officer * * * has probable cause to believe that the person is concealing evidence of the commission of a criminal offense * * * that could not otherwise be discovered.” In the case sub judice,…”
Washington v. Dep't of Rehab. & Corr., 166 Ohio App. 3d 797 (Ohio Ct. App. 2006). “Appellant filed a complaint in the Court of Claims alleging a violation of Ohio’s statute governing strip searches, R.C. 2933.32, and a common-law claim for invasion of privacy.”
State v. Monegan, 2023 Ohio 2130 (Ohio Ct. App. 2023).
— Ohio Rev. Code § 2933.32(B)(5) — 1 case
State v. Jones, 796 N.E.2d 989 (Ohio Ct. App. 2003). “97API12-1587, 1998 WL 655277 , the Tenth District Court of Appeals stated: {¶ 33} “R.C. 2933.32 places express limitations on the manner in which strip searches are to be conducted.”
— Ohio Rev. Code § 2933.32(B)(6) — 3 cases
State v. Mason, 2016 Ohio 7081 (Ohio Ct. App. 2016). “9 {¶25} Finally, Mason argues that the trial court improperly relied on R.C. 2933.32 in upholding the search of her person.”
State v. Jones, 796 N.E.2d 989 (Ohio Ct. App. 2003). “97API12-1587, 1998 WL 655277 , the Tenth District Court of Appeals stated: {¶ 33} “R.C. 2933.32 places express limitations on the manner in which strip searches are to be conducted.”
State v. Murphy, 2014 Ohio 5002 (Ohio Ct. App. 2014).
— Ohio Rev. Code § 2933.32(D)(3) — 2 cases
Deaton v. Burney, 669 N.E.2d 1 (Ohio Ct. App. 1995). “In both their federal and state claims, the plaintiffs alleged that the strip searches were conducted in violation of R.C. 2933.32. In the federal action, the plaintiffs named the city of Dayton, Billy C.”
State v. Murphy, 2014 Ohio 5002 (Ohio Ct. App. 2014).
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