Ohio Revised Code

Ohio Rev. Code § 2945.45 (2026)

Subpoenas to issue to any county

✓ laws through the 2026 session (checked Sept. 2026)

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Effective:

October 1, 1953

Latest Legislation:

House Bill 1 - 100th General Assembly

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In all criminal cases, the clerk of the court of common pleas, upon a praecipe being filed, shall issue writs of subpoena for the witnesses names therein, directed to the sheriff of such county, or the county where such witnesses reside or are found, which shall be served and returned as in other cases. Such sheriff, by writing indorsed on the writs, may depute a disinterested person to serve and return them. The person so deputed to serve such subpoenas shall make a return of the service made, and make oath thereto before a person competent to administer oaths, which shall be indorsed on the writ. The return may be forwarded through the post office, or otherwise.

Notes of Decisions

Cited in 7 cases (4 in the last 5 years), 1961–2026 · leading case: State v. McCrary, 2017-Ohio-8701.

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State v. McCrary, 2017-Ohio-8701. · cites it 6× “On appeal, Appellant contends that 1) the trial judge abused his discretion when he replaced Juror 23 with an alternate pursuant to R.C. 2945.45; and 2) his conviction is against the manifest weight of the evidence.”

State v. Santibanez, 2023-Ohio-3404, 224 N.E.3d 1268. “The manner of enforcing the constitutional right to compulsory process is provided by R.C. 2945.45 (“Subpoenas to issue to any country”) and Crim.”

State v. Wolfe, 2025-Ohio-866. “The manner of enforcing the constitutional right to compulsory process is provided by R.C. 2945.45 (“Subpoenas to issue to any county”) and Crim.”

State v. Ware, 542 N.E.2d 1115 (Ohio Ct. App. 1st Dist. 1988). “3 At the conclusion of the sentencing hearing, the trial court said: “There will be a stay and so forth on the hearing, but if in fact the stay is invalid, it is my intention that he do the time that I commit him to rather to be subjected to R.C. 2945.45 [sic]. In other words,…”

State v. Kinman, 2025-Ohio-4822. · cites it 2× ““The manner of enforcing the constitutional right to compulsory process is provided by R.C. 2945.45 (‘Subpoenas to issue to any country’) and Crim.”

State v. McFarland, 2026-Ohio-835. “The manner in which a defendant’s Section 10 right to compulsory process is enforced is through R.C. 2945.45 (procedure to effectuate defendant’s subpoena) and Crim.”

State v. Bostic, 184 N.E.2d 597 (Ohio Ct. App. 1961). · cites it 2× “See Section 2945.45, Revised Code. In the rulings on motions in regard to examination of the safe, it would appear that the trial court exercised its discretion and from a review of the entire record we cannot say that there was an abuse of discretion, particularly since there…”

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