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Ohio Revised Code

Ohio Rev. Code § 2945.25 (2026)

Challenges for cause

✓ current as of May 2026
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Effective:
April 6, 2023
Latest Legislation:
House Bill 281 - 134th General Assembly
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A person called as a juror in a criminal case may be challenged for the following causes:

(A) That the person was a member of the grand jury that found the indictment in the case;

(B) That the person is possessed of a state of mind evincing enmity or bias toward the defendant or the state; but no person summoned as a juror shall be disqualified by reason of a previously formed or expressed opinion with reference to the guilt or innocence of the accused, if the court is satisfied, from examination of the juror or from other evidence, that the juror will render an impartial verdict according to the law and the evidence submitted to the jury at the trial;

(C) In the trial of a capital offense, that the person unequivocally states that under no circumstances will the person follow the instructions of a trial judge and consider fairly the imposition of a sentence of death in a particular case. A prospective juror's conscientious or religious opposition to the death penalty in and of itself is not grounds for a challenge for cause. All parties shall be given wide latitude in voir dire questioning in this regard.

(D) That the person is related by consanguinity or affinity within the fifth degree to the person alleged to be injured or attempted to be injured by the offense charged, or to the person on whose complaint the prosecution was instituted, or to the defendant;

(E) That the person served on a petit jury drawn in the same cause against the same defendant, and that jury was discharged after hearing the evidence or rendering a verdict on the evidence that was set aside;

(F) That the person served as a juror in a civil case brought against the defendant for the same act;

(G) That the person has been subpoenaed in good faith as a witness in the case;

(H) That the person has chronic alcoholism, or a drug dependency;

(I) That the person has been convicted of a crime that by law disqualifies the person from serving on a jury;

(J) That the person has an action pending between the person and the state or the defendant;

(K) That the person or the person's spouse is a party to another action then pending in any court in which an attorney in the cause then on trial is an attorney, either for or against the person;

(L) That the person is the person alleged to be injured or attempted to be injured by the offense charged, or is the person on whose complaint the prosecution was instituted, or the defendant;

(M) That the person is the employer or employee, or the spouse, parent, son, or daughter of the employer or employee, or the counselor, agent, or attorney of any person included in division (L) of this section;

(N) That English is not the person's native language, and the person's knowledge of English is insufficient to permit the person to understand the facts and law in the case;

(O) That the person otherwise is unsuitable for any other cause to serve as a juror.

The validity of each challenge listed in this section shall be determined by the court.

Last updated January 25, 2023 at 11:22 AM

Notes of Decisions
Cited in 133 cases (21 in the last 5 years), 1955–2025 · leading case: State v. Adams (Slip Opinion), 2015 Ohio 3954 (Ohio 2015).
Sort: Relevance Newest Treatment
State v. Adams (Slip Opinion), 2015 Ohio 3954 (Ohio 2015). · cites it 9× “Dismissal for cause is proper under R.C. 2945.25(0) if “the juror’s views would prevent or substantially impair the performance of his duties as a juror in accordance with his instructions and oath.”
State v. Neyland (Slip Opinion), 2014 Ohio 1914 (Ohio 2014). · cites it 6× “This court has held that if a juror satisfies the Witt criterion, he may be excluded for cause under the catch-all provision of R.C. 2945.25(0) even though he does not satisfy the more specific R.”
State v. Trimble, 2009 Ohio 2961 (Ohio 2009). · cites it 4× “{¶ 78} R.C. 2945.25 provides: {¶ 79} “A person called as a juror in a criminal case may be challenged for the following causes: {¶ 80} “* * * {¶ 81} “(G) That he has been subpoenaed in good faith as a witness in the case; {¶ 82} “* * * {¶ 83} “(O) That he otherwise is unsuitable…”
State v. Jenkins, 473 N.E.2d 264 (Ohio 1984). · cites it 4× “R.C. 2945.25 provides in part that: “A person called as a juror in a criminal case may be challenged for the following causes: * * “(C) In the trial of a capital offense, that he unequivocally states that under no circumstances will he follow the instruction of a trial judge and…”
State v. Thompson (Slip Opinion), 2014 Ohio 4751 (Ohio 2014). · cites it 4× “” R.C. 2945.25(0); Crim.R. 24(C)(14). A trial court’s application of this provision is reversible only for an abuse of discretion.”
State v. Williams, 794 N.E.2d 27 (Ohio 2003). · cites it 4× “We have held that if a juror satisfies the Witt criterion, he may be *500 excluded for cause under the catchall provision of R.C. 2945.25(0) even when he does not satisfy the more specific R.”
State v. Laskey, 257 N.E.2d 65 (Ohio 1970). · cites it 16× “510 , who did not object when, on the voir dire, some prospective jurors who expressed opinions against capital punishment were excused without a conclusive showing that their opinions would preclude them from finding the accused guilty of an offense punishable by death, as…”
State v. Beuke, 526 N.E.2d 274 (Ohio 1988). · cites it 6× “2d 568 ; R.C. 2945.25. No prejudicial error can be assigned the examination of veniremen in qualifying them as fair and impartial jurors unless a clear abuse of discretion is shown.”
State v. Treesh, 739 N.E.2d 749 (Ohio 2001). · cites it 2× “25(C) provides that a prospective juror in a capital punishment case may be challenged for cause where “he unequivocally states that under no circumstances will he follow the instructions of a trial judge and consider fairly the imposition of a sentence of death in a particular…”
State v. Wilks (Slip Opinion), 2018 Ohio 1562 (Ohio 2018). · cites it 2× “{¶ 51} Under R.C. 2945.25(N), a person called for service as a juror in a criminal case may be challenged if “English is not his native language, and his knowledge of English is insufficient to permit him to understand the facts and law in the case.”
State v. Madison (Slip Opinion), 2020 Ohio 3735 (Ohio 2020). · cites it 3× “{¶ 84} Neither R.C. 2945.25 nor Crim.R. 24(C) specifies that limited reading ability is cause for disqualification.”
State v. Buell, 489 N.E.2d 795 (Ohio 1986). · cites it 3× “25(C) does not provide an alternative challenge for cause for such a juror, R.C. 2945.25(0) would allow, if found appropriate, a challenge for cause in such a case in light of Wainwright .”
Show all 133 citing cases →
— Ohio Rev. Code § 2945.25(0) — 9 cases
State v. Adams (Slip Opinion), 2015 Ohio 3954 (Ohio 2015). “Dismissal for cause is proper under R.C. 2945.25(0) if “the juror’s views would prevent or substantially impair the performance of his duties as a juror in accordance with his instructions and oath.”
State v. Thompson (Slip Opinion), 2014 Ohio 4751 (Ohio 2014). “” R.C. 2945.25(0); Crim.R. 24(C)(14). A trial court’s application of this provision is reversible only for an abuse of discretion.”
State v. Williams, 794 N.E.2d 27 (Ohio 2003). “We have held that if a juror satisfies the Witt criterion, he may be *500 excluded for cause under the catchall provision of R.C. 2945.25(0) even when he does not satisfy the more specific R.”
State v. Neyland (Slip Opinion), 2014 Ohio 1914 (Ohio 2014). “This court has held that if a juror satisfies the Witt criterion, he may be excluded for cause under the catch-all provision of R.C. 2945.25(0) even though he does not satisfy the more specific R.”
State v. Buell, 489 N.E.2d 795 (Ohio 1986). “25(C) does not provide an alternative challenge for cause for such a juror, R.C. 2945.25(0) would allow, if found appropriate, a challenge for cause in such a case in light of Wainwright .”
— Ohio Rev. Code § 2945.25(1) — 1 case
State v. Coleman, 544 N.E.2d 622 (Ohio 1989).
— Ohio Rev. Code § 2945.25(A) — 4 cases
State v. Holdcroft, 2010 Ohio 6262 (Ohio Ct. App. 2010).
State v. Holdcroft, 2012 Ohio 3066 (Ohio Ct. App. 2012).
State v. Johnson, 2011 Ohio 2825 (Ohio Ct. App. 2011).
State v. Taylor, 2013 Ohio 471 (Ohio Ct. App. 2013).
— Ohio Rev. Code § 2945.25(B) — 29 cases
State v. Ivery, 2020 Ohio 3349 (Ohio Ct. App. 2020).
State v. Beuke, 526 N.E.2d 274 (Ohio 1988). “2d 568 ; R.C. 2945.25. No prejudicial error can be assigned the examination of veniremen in qualifying them as fair and impartial jurors unless a clear abuse of discretion is shown.”
State v. Vrabel, 99 Ohio St. 3d 184 (Ohio 2003).
State v. Lloyd, 2021 Ohio 1808 (Ohio Ct. App. 2021).
State v. Quinn, 2017 Ohio 7000 (Ohio Ct. App. 2017).
— Ohio Rev. Code § 2945.25(C) — 51 cases
State v. Neyland (Slip Opinion), 2014 Ohio 1914 (Ohio 2014). “This court has held that if a juror satisfies the Witt criterion, he may be excluded for cause under the catch-all provision of R.C. 2945.25(0) even though he does not satisfy the more specific R.”
State v. Adams (Slip Opinion), 2015 Ohio 3954 (Ohio 2015). “Dismissal for cause is proper under R.C. 2945.25(0) if “the juror’s views would prevent or substantially impair the performance of his duties as a juror in accordance with his instructions and oath.”
State v. Treesh, 739 N.E.2d 749 (Ohio 2001). “25(C) provides that a prospective juror in a capital punishment case may be challenged for cause where “he unequivocally states that under no circumstances will he follow the instructions of a trial judge and consider fairly the imposition of a sentence of death in a particular…”
State v. Laskey, 257 N.E.2d 65 (Ohio 1970). “510 , who did not object when, on the voir dire, some prospective jurors who expressed opinions against capital punishment were excused without a conclusive showing that their opinions would preclude them from finding the accused guilty of an offense punishable by death, as…”
State v. Jenkins, 473 N.E.2d 264 (Ohio 1984). “R.C. 2945.25 provides in part that: “A person called as a juror in a criminal case may be challenged for the following causes: * * “(C) In the trial of a capital offense, that he unequivocally states that under no circumstances will he follow the instruction of a trial judge and…”
— Ohio Rev. Code § 2945.25(D) — 1 case
State v. Scoggins, 2017 Ohio 8989 (Ohio Ct. App. 2017).
— Ohio Rev. Code § 2945.25(E) — 1 case
State v. Knuff, 2024 Ohio 902 (Ohio 2024).
— Ohio Rev. Code § 2945.25(N) — 3 cases
State v. Wilks (Slip Opinion), 2018 Ohio 1562 (Ohio 2018). “{¶ 51} Under R.C. 2945.25(N), a person called for service as a juror in a criminal case may be challenged if “English is not his native language, and his knowledge of English is insufficient to permit him to understand the facts and law in the case.”
State v. Smith, 2013 Ohio 1586 (Ohio Ct. App. 2013).
State v. Frazier, 2012 Ohio 790 (Ohio Ct. App. 2012).
— Ohio Rev. Code § 2945.25(O) — 17 cases
State v. Adams (Slip Opinion), 2015 Ohio 3954 (Ohio 2015). “Dismissal for cause is proper under R.C. 2945.25(0) if “the juror’s views would prevent or substantially impair the performance of his duties as a juror in accordance with his instructions and oath.”
State v. Madison (Slip Opinion), 2020 Ohio 3735 (Ohio 2020). “{¶ 84} Neither R.C. 2945.25 nor Crim.R. 24(C) specifies that limited reading ability is cause for disqualification.”
State v. Thompson (Slip Opinion), 2014 Ohio 4751 (Ohio 2014). “” R.C. 2945.25(0); Crim.R. 24(C)(14). A trial court’s application of this provision is reversible only for an abuse of discretion.”
State v. Neyland (Slip Opinion), 2014 Ohio 1914 (Ohio 2014). “This court has held that if a juror satisfies the Witt criterion, he may be excluded for cause under the catch-all provision of R.C. 2945.25(0) even though he does not satisfy the more specific R.”
State v. Tyler, 553 N.E.2d 576 (Ohio 1990).
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