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Ohio Revised Code

Ohio Rev. Code § 2945.392 (2026)

Expert testimony of the battered woman syndrome

✓ current as of May 2026

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Effective:

July 1, 1997

Latest Legislation:

Senate Bill 285 - 121st General Assembly

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(A) The declarations set forth in division (A) of section 2901.06 of the Revised Code apply in relation to this section.

(B) If a defendant is charged with an offense involving the use of force against another and the defendant enters a plea to the charge of not guilty by reason of insanity, the defendant may introduce expert testimony of the "battered woman syndrome" and expert testimony that the defendant suffered from that syndrome as evidence to establish the requisite impairment of the defendant's reason, at the time of the commission of the offense, that is necessary for a finding that the defendant is not guilty by reason of insanity. The introduction of any expert testimony under this division shall be in accordance with the Ohio Rules of Evidence.

Notes of Decisions

Cited in 4 cases, 1994–2020 · leading case: State v. Haines, 2006 Ohio 6711 (Ohio 2006).

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State v. Haines, 2006 Ohio 6711 (Ohio 2006). · cites it 4× “” 10 January Term, 2006 {¶ 41} The General Assembly also enacted R.C. 2945.392, which allows battered-woman-syndrome testimony to be admitted by a defendant that pleads not guilty by reason of insanity.”

State v. McEndree, 2020 Ohio 4526 (Ohio Ct. App. 2020). · cites it 3× “{¶71} R.C. 2945.392(B), which governs “battered woman syndrome,” specifically states that “[i]f a defendant is charged with an offense involving the use of force against another and the defendant enters a plea to the charge of not guilty by reason of insanity, the defendant may…”

State v. Goff, 2010 Ohio 6317 (Ohio 2010). · cites it 2× “” {¶ 70} Similarly, R.C. 2945.392 permits a defendant to introduce expert testimony of battered woman’s syndrome if she enters a plea to the charge of not guilty by reason of insanity in order “to establish the requisite impairment of the defendant’s reason, at the time of the…”

State v. Daws, 662 N.E.2d 805 (Ohio Ct. App. 1994). “The General Assembly also enacted R.C. 2945.392 "to specifically authorize expert testimony relative to the * * * ‘battered woman syndrome’ * * * to establish the impairment of reason that is an element of a finding of not guilty by reason of insanity.”

— Ohio Rev. Code § 2945.392(B) — 1 case

State v. McEndree, 2020 Ohio 4526 (Ohio Ct. App. 2020). “{¶71} R.C. 2945.392(B), which governs “battered woman syndrome,” specifically states that “[i]f a defendant is charged with an offense involving the use of force against another and the defendant enters a plea to the charge of not guilty by reason of insanity, the defendant may…”

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