Ohio Revised Code

Ohio Rev. Code § 2935.09 (2026)

Person having knowledge of offense to file affidavit - official review before complaint filed

✓ current as of May 2026
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(A) As used in this section, "reviewing official" means a judge of a court of record, the prosecuting attorney or attorney charged by law with the prosecution of offenses in a court or before a magistrate, or a magistrate.

(B) In all cases not provided by sections 2935.02 to 2935.08 of the Revised Code, in order to cause the arrest or prosecution of a person charged with committing an offense in this state, a peace officer or a private citizen having knowledge of the facts shall comply with this section.

(C) A peace officer who seeks to cause an arrest or prosecution under this section may file with a reviewing official or the clerk of a court of record an affidavit charging the offense committed.

(D) A private citizen having knowledge of the facts who seeks to cause an arrest or prosecution under this section may file an affidavit charging the offense committed with a reviewing official for the purpose of review to determine if a complaint should be filed by the prosecuting attorney or attorney charged by law with the prosecution of offenses in the court or before the magistrate. A private citizen may file an affidavit charging the offense committed with the clerk of a court of record before or after the normal business hours of the reviewing officials if the clerk's office is open at those times. A clerk who receives an affidavit before or after the normal business hours of the reviewing officials shall forward it to a reviewing official when the reviewing official's normal business hours resume.

Notes of Decisions
Cited in 115 cases (30 in the last 5 years), 1962–2026 · leading case: State v. Mbodji, 2011 Ohio 2880 (Ohio 2011).
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State v. Mbodji, 2011 Ohio 2880 (Ohio 2011). · cites it 38× “A complaint that meets the requirements of Crim.”
State ex rel. Blachere v. Tyack, 2023 Ohio 781 (Ohio Ct. App. 2023). · cites it 43× “Tyack, Franklin County Municipal Court Clerk ("Clerk Tyack"), and Maryellen O'Shaughnessy, Franklin County Clerk of Courts ("Clerk O'Shaughnessy"), to accept for filing the affidavit he presented to Clerk Tyack pursuant to R.C. 2935.09 and 2935.10. For the foregoing reasons, we…”
State ex rel. Brown v. Nusbaum (Slip Opinion), 2017 Ohio 9141 (Ohio 2017). · cites it 7× “Background {¶ 2} In September 2014, Brown filed a demand and a supporting affidavit in the Ross County Common Pleas Court under R.C. 2935.09. He sought the issuance of criminal warrants against numerous employees of Aramark Correctional Services, Inc.”
Hillman v. O'Shaughnessy, 2017 Ohio 489 (Ohio Ct. App. 2017). · cites it 13× “Factual and Procedural Background {¶ 2} On July 8, 2016, Hillman, an inmate at the Chillicothe Correctional Institution, filed an affidavit pursuant to R.C. 2935.09 and 2935.10 accusing defendant- appellee, Maryellen O'Shaughnessy, Franklin County Clerk of Courts ("Clerk of…”
State v. Fraley, 2020 Ohio 3763 (Ohio Ct. App. 2020). · cites it 18× “{¶ 1} Appellant, Christopher Hicks, appeals judgments of the Clermont County Municipal Court that (1) refused to issue an arrest warrant or summons in response to an Clermont CA2019-09-072 2 affidavit Hicks filed pursuant to R.C. 2935.09(D) that alleged the commission of a…”
Hillman v. Larrison, 2016 Ohio 666 (Ohio Ct. App. 2016). · cites it 15× “Appellant's affidavit specifically indicated it was being filed, pursuant to R.C. 2935.09 and 2935.10, which permit a private citizen to file an affidavit charging an offense against another person.”
State v. Burns, 2019 Ohio 1141 (Ohio Ct. App. 2019). · cites it 29× “eal: APPELLANT CONTENDS THAT THE TRIAL COURT JUDGE DENIED HIM HIS RIGHTS UNDER THE 1ST, 5TH, AND 14TH AMENDMENTS TO THE UNITED STATES CONSTITUTIONS TO MEANINGFUL ACCESS TO THE COURT, AND THE RIGHT TO PETITION -4- THE GOVERNMENT FOR REDRESS OF INJURIES WHICH DENIED HIM DUE…”
State ex rel. Bunting v. Styer (Slip Opinion), 2016 Ohio 5781 (Ohio 2016). · cites it 5× “09(D) allows a private citizen to file an affidavit alleging a criminal offense: A private citizen having knowledge of the facts who seeks to cause an arrest or prosecution under this section may file an affidavit charging the offense committed with a reviewing official for the…”
State ex rel. Whittaker v. Lucas Cty. Prosecutor's Off. (Slip Opinion), 2021 Ohio 1241 (Ohio 2021). · cites it 4× “] Mandamus—R.C. 2935.09—Citizen affidavits—Appellant lacks clear legal right to prosecution of felonious-assault charges—Court of appeals’ grant of summary judgment in favor of prosecutor affirmed.”
State ex rel. A.N. v. Cuyahoga Cty. Prosecutor's Off. (Slip Opinion), 2021 Ohio 2071 (Ohio 2021). · cites it 4× “’s complaint avers that he brought his parents’ alleged crimes to the attention of the city prosecutor, who then referred the matter to the county prosecutor’s office.”
State v. L.F., 2020 Ohio 968 (Ohio Ct. App. 2020). · cites it 8× “{¶ 14} Notably, R.C. 2935.09 and 2935.10 only permit a private citizen to file an affidavit charging an offense.”
State ex rel. Brown v. Jeffries, 2012 Ohio 1522 (Ohio Ct. App. 2012). · cites it 7× “FACTS {¶2} While incarcerated in Ross Correctional Institute, Steven Brown filed an affidavit with the Ross County Court of Common Pleas seeking the issuance of criminal warrants under R.C. 2935.09 against several prison officials for committing both felonies and misdemeanor…”
Show all 115 citing cases →
— Ohio Rev. Code § 2935.09(A) — 19 cases
State ex rel. Blachere v. Tyack, 2023 Ohio 781 (Ohio Ct. App. 2023). “Tyack, Franklin County Municipal Court Clerk ("Clerk Tyack"), and Maryellen O'Shaughnessy, Franklin County Clerk of Courts ("Clerk O'Shaughnessy"), to accept for filing the affidavit he presented to Clerk Tyack pursuant to R.C. 2935.09 and 2935.10. For the foregoing reasons, we…”
State v. Mbodji, 2011 Ohio 2880 (Ohio 2011). “A complaint that meets the requirements of Crim.”
Hillman v. Larrison, 2016 Ohio 666 (Ohio Ct. App. 2016). “Appellant's affidavit specifically indicated it was being filed, pursuant to R.C. 2935.09 and 2935.10, which permit a private citizen to file an affidavit charging an offense against another person.”
State ex rel. Evans v. Tieman (Slip Opinion), 2019 Ohio 2411 (Ohio 2019).
State ex rel. Brown v. Jeffries, 2012 Ohio 1522 (Ohio Ct. App. 2012). “FACTS {¶2} While incarcerated in Ross Correctional Institute, Steven Brown filed an affidavit with the Ross County Court of Common Pleas seeking the issuance of criminal warrants under R.C. 2935.09 against several prison officials for committing both felonies and misdemeanor…”
— Ohio Rev. Code § 2935.09(B) — 1 case
State v. Roby, 2017 Ohio 7331 (Ohio Ct. App. 2017).
— Ohio Rev. Code § 2935.09(C) — 6 cases
State ex rel. Blachere v. Tyack, 2023 Ohio 781 (Ohio Ct. App. 2023). “Tyack, Franklin County Municipal Court Clerk ("Clerk Tyack"), and Maryellen O'Shaughnessy, Franklin County Clerk of Courts ("Clerk O'Shaughnessy"), to accept for filing the affidavit he presented to Clerk Tyack pursuant to R.C. 2935.09 and 2935.10. For the foregoing reasons, we…”
State v. Bell, 2019 Ohio 340 (Ohio Ct. App. 2019).
State v. Cole, 2012 Ohio 4027 (Ohio Ct. App. 2012).
State v. Jones, 2012 Ohio 1301 (Ohio Ct. App. 2012).
State v. Lindstrom, 2011 Ohio 6755 (Ohio Ct. App. 2011).
— Ohio Rev. Code § 2935.09(D) — 52 cases
State ex rel. Blachere v. Tyack, 2023 Ohio 781 (Ohio Ct. App. 2023). “Tyack, Franklin County Municipal Court Clerk ("Clerk Tyack"), and Maryellen O'Shaughnessy, Franklin County Clerk of Courts ("Clerk O'Shaughnessy"), to accept for filing the affidavit he presented to Clerk Tyack pursuant to R.C. 2935.09 and 2935.10. For the foregoing reasons, we…”
State v. Mbodji, 2011 Ohio 2880 (Ohio 2011). “A complaint that meets the requirements of Crim.”
State v. Fraley, 2020 Ohio 3763 (Ohio Ct. App. 2020). “{¶ 1} Appellant, Christopher Hicks, appeals judgments of the Clermont County Municipal Court that (1) refused to issue an arrest warrant or summons in response to an Clermont CA2019-09-072 2 affidavit Hicks filed pursuant to R.C. 2935.09(D) that alleged the commission of a…”
State ex rel. A.N. v. Cuyahoga Cty. Prosecutor's Off. (Slip Opinion), 2021 Ohio 2071 (Ohio 2021). “’s complaint avers that he brought his parents’ alleged crimes to the attention of the city prosecutor, who then referred the matter to the county prosecutor’s office.”
State ex rel. Brown v. Nusbaum (Slip Opinion), 2017 Ohio 9141 (Ohio 2017). “Background {¶ 2} In September 2014, Brown filed a demand and a supporting affidavit in the Ross County Common Pleas Court under R.C. 2935.09. He sought the issuance of criminal warrants against numerous employees of Aramark Correctional Services, Inc.”
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