Ohio Revised Code

Ohio Rev. Code § 2945.03 (2026)

Control of trial

✓ current as of May 2026
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The judge of the trial court shall control all proceedings during a criminal trial, and shall limit the introduction of evidence and the argument of counsel to relevant and material matters with a view to expeditious and effective ascertainment of the truth regarding the matters in issue.

Notes of Decisions
Cited in 60 cases (11 in the last 5 years), 1964–2026 · leading case: State v. Bradley, 538 N.E.2d 373 (Ohio 1989).
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State v. Bradley, 538 N.E.2d 373 (Ohio 1989). “611(A) and R.C. 2945.03 to allow a witness to make a statement unrelated to any material fact of the case.”
State v. Richey, 595 N.E.2d 915 (Ohio 1992). · cites it 2× “See R.C. 2945.03. Even though the judges had been exposed to evidence about Richey’s threats, they did not need to recuse themselves.”
State v. Costell, 2016-Ohio-3386. · cites it 2× “Indeed, R.C. 2945.03 provides: The judge of the trial court shall control all proceedings during a criminal trial, and shall limit the introduction of evidence and the argument of counsel to relevant and material matters with a view to expeditious and effective ascertainment of…”
State v. Heiney, 2018-Ohio-3408, 117 N.E.3d 1034. · cites it 2× “" Moments later, at the completion of Downard's testimony, defense counsel again asked about making the proffer.”
State v. Leonard, 818 N.E.2d 229 (Ohio 2004). “27 affords the prosecution and defense the opportunity to conduct a reasonable examination of prospective jurors, * * * the trial court reserves the right and responsibility to control the proceedings of a criminal trial pursuant to R.C. 2945.03, and must limit the trial to…”
State v. Nields, 752 N.E.2d 859 (Ohio 2001). “R.C. 2945.03 provides, “The judge of the trial court shall control all proceedings during a criminal trial, and shall limit the introduction of evidence and- the argument of counsel to relevant and material matters with a view to expeditious and effective ascertainment of the…”
State v. Gross, 2002-Ohio-5524, 97 Ohio St. 3d 121. “Voir dire lasted eleven days, encompassed over 2,500 pages of transcript, and, as we noted in our discussion on venue, featured extensive examination of the prospective jurors by the court, the state, and defense counsel.”
State v. Getsy, 702 N.E.2d 866 (Ohio 1998). “27 affords the prosecution and defense the opportunity to conduct a reasonable examination of prospective jurors, * * * the trial court reserves the right and responsibility to control the proceedings of a criminal trial pursuant to R.C. 2945.03, and must limit the trial to…”
State v. Richey, 1992 Ohio 44 (Ohio 1992). · cites it 2× “See R.C. 2945.03. Even though the judges had been exposed to evidence about Richey's threats, they did not need to recuse themselves.”
State v. Randle, 2018-Ohio-207, 104 N.E.3d 202. “We do not find evidence in the record that suggests the trial court abused this discretion in ordering the recess or in denying Randle's motion for a mistrial.”
State v. Lorraine, 613 N.E.2d 212 (Ohio 1993). “27 affords the prosecution and defense the opportunity to conduct a reasonable examination of prospective jurors, * * * the trial court reserves the right and responsibility to control the proceedings of a criminal trial pursuant to R.C. 2945.03, and must limit the trial to…”
State v. Adams, 2011-Ohio-5361. · cites it 2× “See, also, R.C. 2945.03. The proper scope and manner of voir dire is within the trial court's discretion and varies with the circumstances of each case.”
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