Ohio Revised Code

Ohio Rev. Code § 2939.20 (2026)

Concurrence by twelve grand jurors for indictment

✓ laws through the 2026 session (checked Sept. 2026)
Find cases: SyfertCases citing this section ORCcodes.ohio.gov (official) Justiaon Justia CornellLII Search CasesGoogle Scholar

At least twelve of the grand jurors must concur in the finding of an indictment. When so found, the foreman shall indorse on such indictment the words "A true bill" and subscribe his name as foreman.

Notes of Decisions
Cited in 21 cases (7 in the last 5 years), 1988–2026 · leading case: State v. Brown, 528 N.E.2d 523 (Ohio 1988).
Sort: Relevance Newest Treatment
State v. Brown, 528 N.E.2d 523 (Ohio 1988). · cites it 2× “R.C. 2939.20 requires twelve of fifteen people to agree before an indictment is issued.”
State v. Holmes, 2019-Ohio-2485, 139 N.E.3d 574. · cites it 2× “In addition, R.C. 2939.20 requires that “[a]t least twelve of the grand jurors -5- Case No.”
State v. Payne, 899 N.E.2d 1011 (Ohio Ct. App. 9th Dist. 2008). · cites it 2× “{¶ 21} In his fourth assignment of error, Payne argues that his indictment was invalid because it was initialed, rather than signed, by the grand jury foreperson.”
State v. Coleman, 2023-Ohio-4354. · cites it 2× “6 and R.C. 2939.20. Appellant's Preliminary Hearing Arguments {¶ 9} Appellant did not raise the preliminary hearing issue in his PPCR.”
Payne v. Jeffreys, 109 Ohio St. 3d 239 (2006). · cites it 3× “Payne claimed that he was entitled to the writ because his indictment violated R.C. 2939.20 and thereby rendered the indictment “of no legal force.”
State v. Pitts, 2025-Ohio-2703. · cites it 2× “{¶ 12} Pitts argues the grand jury foreperson failed to sign the indictment with the words "A True Bill" in violation of R.C. 2939.20 ("At least twelve of the grand jurors must concur in the finding of an indictment.”
State v. Burnside, 2010-Ohio-3158. “Presumably, Appellant is referring to the requirements of R.C. 2939.20, which states: “At least twelve of the grand jurors must concur in the finding of an indictment.”
State v. L.F., 2020-Ohio-420, 151 N.E.3d 970. “R.C. 2939.20; Crim.R. 7(A). {¶ 13} Because L.”
State v. Hatton, 2012-Ohio-2019. “R.C.2939.20 provides: ‘At least twelve of the grand jurors must concur in the finding of an indictment.”
State v. Payne, 2012-Ohio-1334. · cites it 4× “{¶7} R.C. 2939.20 states, “At least twelve of the grand jurors must concur in the finding of an indictment.”
State v. Allen, 2018-Ohio-878. “Ohio Constitution, Article I, Section 10; R.C. 2939.20. An indictment specifies “in ordinary and concise language without technical averments or allegations not essential to be proved” that the defendant has committed a public offense.”
State v. Shutway, 2020-Ohio-5035. · cites it 2× “” R.C. 2939.20 also requires the grand-jury foreperson to sign the indictment, as well as indorse the indictment with the words “A true -18- bill.”
Show all 21 citing cases →
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.