Ohio Revised Code

Ohio Rev. Code § 2935.04 (2026)

When any person may arrest

✓ current as of May 2026
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When a felony has been committed, or there is reasonable ground to believe that a felony has been committed, any person without a warrant may arrest another whom he has reasonable cause to believe is guilty of the offense, and detain him until a warrant can be obtained.

Notes of Decisions
Cited in 42 cases (6 in the last 5 years), 1954–2023 · leading case: State v. Jordan (Slip Opinion), 2021 Ohio 3922 (Ohio 2021).
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State v. Jordan (Slip Opinion), 2021 Ohio 3922 (Ohio 2021). · cites it 38× “] Criminal law—Warrantless arrest—R.C. 2935.04—Neither a showing of exigent circumstances nor a showing of the impracticability of obtaining an arrest warrant is necessary to sustain the constitutionality of a warrantless arrest under either the United States Constitution or the…”
State v. Williams, 452 N.E.2d 1323 (Ohio 1983). · cites it 2× “In effecting appellant’s arrest, the police officers were acting in accordance with the explicit language and judicial interpretation of R.C. 2935.04. The statute provides that: “When a felony has been committed, or there is reasonable ground to believe that a felony has been…”
State v. Walker, 2016 Ohio 3499 (Ohio Ct. App. 2016). “” R.C. 2935.04. The evidence as known by the officers in this case is that 1) there was a pair of pants which had drugs and a large amount of cash in the pockets, 2) the pants allegedly belonged to someone known as “Moes”, 3) “Moes” was allegedly coming to pick up the drugs, 4)…”
State v. Elmore, 857 N.E.2d 547 (Ohio 2006). “04 provides: “When a felony has been committed, or there is reasonable ground to believe that a felony has been committed, any person without a warrant may arrest another whom he has reasonable cause to believe is guilty of the offense, and detain him until a warrant can be…”
State v. Brown, 873 N.E.2d 858 (Ohio 2007). “Warrantless arrests for felony-offenses are explicitly permitted in Ohio: R.C. 2935.04 allows for a suspect to be detained until a warrant can be obtained.”
State v. Armstead, 2015 Ohio 5010 (Ohio Ct. App. 2015). · cites it 7× “The State further argues that if Armstead was arrested, the arrest did not violate R.C. 2935.04. However, if a violation of R.”
State v. VanNoy, 934 N.E.2d 413 (Ohio Ct. App. 2010). · cites it 3× “The court reasoned that R.C. 2935.04 permitted the police to arrest VanNoy in a public place for a felony without a warrant.”
State v. Woodards, 215 N.E.2d 568 (Ohio 1966). · cites it 2× “The assertion of invalidity is based upon the lack of probable cause for arrest, the failure to obtain a warrant, and the failure to inform defendant of the charge against him.”
State v. Cobb, 2021 Ohio 3877 (Ohio Ct. App. 2021). · cites it 2× “{¶56} In arguing that a private citizen has “authority to use deadly force * * * to halt a fleeing felon,” Cobb references R.C. 2935.04, which reads as follows: When a felony has been committed, or there is reasonable ground to believe that a felony has been committed, any…”
State v. Phillips, 2016 Ohio 5944 (Ohio Ct. App. 2016). “04 provides that "[w]hen a felony has been committed, or there is reasonable ground to believe that a felony has been committed, any person without a warrant may arrest another whom he has reasonable cause to believe is guilty of the offense, and detain him until a warrant can…”
State v. Harrison (Slip Opinion), 2021 Ohio 4465 (Ohio 2021). “Under R.C. 2935.04, any person without a warrant may arrest another person whom he has reasonable cause to believe is guilty of having committed a felony and may detain that person until a warrant can be obtained.”
State v. Fultz, 234 N.E.2d 593 (Ohio 1968). · cites it 2× “* * *” Furthermore, Section 2935.04, Revised Code, reads as follows: “When a felony has been committed, or there is.”
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