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Ohio Revised Code

Ohio Rev. Code § 2967.01 (2026)

Pardon - parole - probation definitions

✓ current as of May 2026
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Effective:
March 22, 2019
Latest Legislation:
Senate Bill 201 - 132nd General Assembly
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As used in this chapter:

(A) "State correctional institution" includes any institution or facility that is operated by the department of rehabilitation and correction and that is used for the custody, care, or treatment of criminal, delinquent, or psychologically or psychiatrically disturbed offenders.

(B) "Pardon" means the remission of penalty by the governor in accordance with the power vested in the governor by the constitution.

(C) "Commutation" or "commutation of sentence" means the substitution by the governor of a lesser for a greater punishment. A stated prison term may be commuted without the consent of the convict, except when granted upon the acceptance and performance by the convict of conditions precedent. After commutation, the commuted prison term shall be the only one in existence. The commutation may be stated in terms of commuting from a named offense to a lesser included offense with a shorter prison term, in terms of commuting from a stated prison term in months and years to a shorter prison term in months and years, or in terms of commuting from any other stated prison term to a shorter prison term.

(D) "Reprieve" means the temporary suspension by the governor of the execution of a sentence or prison term. The governor may grant a reprieve without the consent of and against the will of the convict.

(E) "Parole" means, regarding a prisoner who is serving a prison term for aggravated murder or murder, who is serving a prison term of life imprisonment for rape or for felonious sexual penetration as it existed under section 2907.12 of the Revised Code prior to September 3, 1996, or who was sentenced prior to July 1, 1996, a release of the prisoner from confinement in any state correctional institution by the adult parole authority that is subject to the eligibility criteria specified in this chapter and that is under the terms and conditions, and for the period of time, prescribed by the authority in its published rules and official minutes or required by division (A) of section 2967.131 of the Revised Code or another provision of this chapter.

(F) "Head of a state correctional institution" or "head of the institution" means the resident head of the institution and the person immediately in charge of the institution, whether designated warden, superintendent, or any other name by which the head is known.

(G) "Convict" means a person who has been convicted of a felony under the laws of this state, whether or not actually confined in a state correctional institution, unless the person has been pardoned or has served the person's sentence or prison term.

(H) "Prisoner" means a person who is in actual confinement in a state correctional institution.

(I) "Parolee" means any inmate who has been released from confinement on parole by order of the adult parole authority or conditionally pardoned, who is under supervision of the adult parole authority and has not been granted a final release, and who has not been declared in violation of the inmate's parole by the authority or is performing the prescribed conditions of a conditional pardon.

(J) "Releasee" means an inmate who has been released from confinement pursuant to section 2967.28 of the Revised Code under a period of post-release control that includes one or more post-release control sanctions.

(K) "Final release" means a remission by the adult parole authority of the balance of the sentence or prison term of a parolee or prisoner or the termination by the authority of a term of post-release control of a releasee.

(L) "Parole violator" or "release violator" means any parolee or releasee who has been declared to be in violation of the condition of parole or post-release control specified in division (A) or (B) of section 2967.131 of the Revised Code or in violation of any other term, condition, or rule of the parolee's or releasee's parole or of the parolee's or releasee's post-release control sanctions, the determination of which has been made by the adult parole authority and recorded in its official minutes.

(M) "Administrative release" means a termination of jurisdiction over a particular sentence or prison term by the adult parole authority for administrative convenience.

(N) "Post-release control" means a period of supervision by the adult parole authority after a prisoner's release from imprisonment, other than under a term of life imprisonment, that includes one or more post-release control sanctions imposed under section 2967.28 of the Revised Code.

(O) "Post-release control sanction" means a sanction that is authorized under sections 2929.16 to 2929.18 of the Revised Code and that is imposed upon a prisoner upon the prisoner's release from a prison term other than a term of life imprisonment.

(P) "Community control sanction," "prison term," "mandatory prison term," and "stated prison term" have the same meanings as in section 2929.01 of the Revised Code.

(Q) "Transitional control" means control of a prisoner under the transitional control program established by the department of rehabilitation and correction under section 2967.26 of the Revised Code, if the department establishes a program of that nature under that section.

(R) "Random drug testing" has the same meaning as in section 5120.63 of the Revised Code.

(S) "Non-life felony indefinite prison term" has the same meaning as in section 2929.01 of the Revised Code.
Notes of Decisions
Cited in 93 cases (28 in the last 5 years), 1967–2026 · leading case: State ex rel. Maurer v. Sheward, 1994 Ohio 496 (Ohio 1994).
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State ex rel. Maurer v. Sheward, 1994 Ohio 496 (Ohio 1994). · cites it 8× “” In addition, R.C. 2967.01(B)’s provision that pardons may be “partial,” and the Peters and Gordon courts’ recognition of partial pardons, further demonstrate that a “full and absolute pardon” is only one type of pardon, and that there is an overlap between the generic sense of…”
State v. Bishop (Slip Opinion), 2018 Ohio 5132 (Ohio 2018). · cites it 2× “” R.C. 2967.01(N). The parole board has authority to impose “conditions of release under a post-release control sanction that the board or court considers appropriate, and the conditions of release may include [a] community residential sanction, community nonresidential…”
State v. Clark, 893 N.E.2d 462 (Ohio 2008). · cites it 2× “R.C. 2967.01(E). *250 Accordingly, parole is neither a part of a maximum penalty nor a consequence of a guilty plea.”
State v. Joseph, 2010 Ohio 954 (Ohio 2010). · cites it 2× “R.C. 2967.01(0) and 2947.23. If the state does not appeal an erroneous sentence within 30 days, it should not be allowed to turn back the clock, as if the sentence did not occur.”
State v. Henderson (Slip Opinion), 2020 Ohio 4784 (Ohio 2020). “3 SUPREME COURT OF OHIO {¶ 3} On March 31, 2009, Henderson filed a motion for sentencing in which he argued that his sentence was unconstitutional and void because the judge imposed a term of postrelease control.”
Woods v. Telb, 733 N.E.2d 1103 (Ohio 2000). · cites it 2× “” R.C. 2967.01(0). Those sections do not deal with prison terms at all, which are dealt with in R.”
State v. Taylor, 676 N.E.2d 82 (Ohio 1997). · cites it 2× “609(C); R.C. 2967.01(B) and (C). We reject proposition of law VII.”
State v. Martello, 780 N.E.2d 250 (Ohio 2002). · cites it 2× “28(F)(3) authorizes the Parole Board to impose a prison term if the board determines after a hearing that a person released on postrelease control (a “releasee,” see R.C. 2967.01[J]) has violated the sanctions or conditions of the postrelease control.”
Ohio Adult Parole Auth. v. Woodard, 523 U.S. 272 (1998). · cites it 2× “III, § 11, Ohio Rev. Code Ann. §§ 2967.01 to 2967.12 (1996); Okla.”
State v. Martello, 2002 Ohio 6661 (Ohio 2002). · cites it 2× “28(F)(3) authorizes the Parole Board to 4 January Term, 2002 impose a prison term if the board determines after a hearing that a person released on postrelease control (a “releasee,” see R.C. 2967.01[J]) has violated the sanctions or conditions of the postrelease control.”
Michael Stansell v., 828 F.3d 412 (6th Cir. 2016). “Ohio Rev. Code § 2967.01(N). As a few examples, the individual might have to undergo random drug testing, live in a halfway house, or maintain employment.”
State v. Bates (Slip Opinion), 2022 Ohio 475 (Ohio 2022). “{¶ 21} At its core, postrelease control is a sanction; it is an additional term of supervision after an offender’s release from prison that imposes certain restrictions on the offender and, if violated, it allows the APA to impose conditions and consequences, including prison…”
Show all 93 citing cases →
— Ohio Rev. Code § 2967.01(0) — 2 cases
State v. Joseph, 2010 Ohio 954 (Ohio 2010). “R.C. 2967.01(0) and 2947.23. If the state does not appeal an erroneous sentence within 30 days, it should not be allowed to turn back the clock, as if the sentence did not occur.”
Woods v. Telb, 733 N.E.2d 1103 (Ohio 2000). “” R.C. 2967.01(0). Those sections do not deal with prison terms at all, which are dealt with in R.”
— Ohio Rev. Code § 2967.01(1) — 2 cases
Crangle v. Kelly, 838 F.3d 673 (5th Cir. 2016).
Knight v. Stickrath, 531 N.E.2d 716 (Ohio 1988).
— Ohio Rev. Code § 2967.01(A) — 5 cases
Adkins v. McFaul, 667 N.E.2d 1171 (Ohio 1996).
State v. Barrett, 945 N.E.2d 1070 (Ohio Ct. App. 2010).
State v. Noel, 2014 Ohio 2231 (Ohio Ct. App. 2014).
Adkins v. McFaul, 1996 Ohio 388 (Ohio 1996).
State ex rel. West v. Hoying, 2025 Ohio 660 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2967.01(B) — 7 cases
State ex rel. Maurer v. Sheward, 1994 Ohio 496 (Ohio 1994). “” In addition, R.C. 2967.01(B)’s provision that pardons may be “partial,” and the Peters and Gordon courts’ recognition of partial pardons, further demonstrate that a “full and absolute pardon” is only one type of pardon, and that there is an overlap between the generic sense of…”
State v. Taylor, 676 N.E.2d 82 (Ohio 1997). “609(C); R.C. 2967.01(B) and (C). We reject proposition of law VII.”
State v. Boykin, 2013 Ohio 4582 (Ohio 2013).
Parker, Springer Jr., Anderson v. Comm. for Sustainable Ret. in Support of Initiative, 314 P.3d 100 (Ariz. Ct. App. 2013).
State v. Taylor, 1997 Ohio 243 (Ohio 1997).
— Ohio Rev. Code § 2967.01(C) — 8 cases
State ex rel. Maurer v. Sheward, 1994 Ohio 496 (Ohio 1994). “” In addition, R.C. 2967.01(B)’s provision that pardons may be “partial,” and the Peters and Gordon courts’ recognition of partial pardons, further demonstrate that a “full and absolute pardon” is only one type of pardon, and that there is an overlap between the generic sense of…”
State v. Taylor, 676 N.E.2d 82 (Ohio 1997). “609(C); R.C. 2967.01(B) and (C). We reject proposition of law VII.”
State v. Taylor, 1997 Ohio 243 (Ohio 1997).
State v. Boykin, 2012 Ohio 1381 (Ohio Ct. App. 2012).
State v. Staffrey, 2025 Ohio 2889 (Ohio 2025).
— Ohio Rev. Code § 2967.01(D) — 2 cases
State ex rel. Maurer v. Sheward, 1994 Ohio 496 (Ohio 1994). “” In addition, R.C. 2967.01(B)’s provision that pardons may be “partial,” and the Peters and Gordon courts’ recognition of partial pardons, further demonstrate that a “full and absolute pardon” is only one type of pardon, and that there is an overlap between the generic sense of…”
State ex rel. Maurer v. Sheward, 1994 Ohio 496 (Ohio 1994).
— Ohio Rev. Code § 2967.01(E) — 12 cases
State v. Henderson (Slip Opinion), 2020 Ohio 4784 (Ohio 2020). “3 SUPREME COURT OF OHIO {¶ 3} On March 31, 2009, Henderson filed a motion for sentencing in which he argued that his sentence was unconstitutional and void because the judge imposed a term of postrelease control.”
State v. Clark, 893 N.E.2d 462 (Ohio 2008). “R.C. 2967.01(E). *250 Accordingly, parole is neither a part of a maximum penalty nor a consequence of a guilty plea.”
State v. Greer, 530 N.E.2d 382 (Ohio 1988).
Williams v. Morris, 584 N.E.2d 671 (Ohio 1992).
Palmer v. Ghee, 690 N.E.2d 73 (Ohio Ct. App. 1997).
— Ohio Rev. Code § 2967.01(H) — 2 cases
State v. Berger, 477 N.E.2d 473 (Ohio Ct. App. 1984).
State v. Talbert, 2025 Ohio 3116 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2967.01(I) — 1 case
Thomas Crangle v. Bennie Kelly (6th Cir. 2016).
— Ohio Rev. Code § 2967.01(J) — 4 cases
Est. of Tokes v. Dept. of Rehab. & Corr., 2019 Ohio 1794 (Ohio Ct. App. 2019).
Tokes v. Dept. of Rehab. & Corr., 2018 Ohio 4149 (Ohio Ct. Cl. 2018).
State ex rel. West v. Hoying, 2025 Ohio 660 (Ohio Ct. App. 2025).
State v. Bevington, 2012 Ohio 6285 (Ohio Ct. App. 2012).
— Ohio Rev. Code § 2967.01(K) — 1 case
State v. Bevington, 2012 Ohio 6285 (Ohio Ct. App. 2012).
— Ohio Rev. Code § 2967.01(L) — 1 case
Jackson v. Ohio Dept. of Rehab. & Corr., 2021 Ohio 1642 (Ohio Ct. App. 2021).
— Ohio Rev. Code § 2967.01(N) — 46 cases
State v. Bishop (Slip Opinion), 2018 Ohio 5132 (Ohio 2018). “” R.C. 2967.01(N). The parole board has authority to impose “conditions of release under a post-release control sanction that the board or court considers appropriate, and the conditions of release may include [a] community residential sanction, community nonresidential…”
State v. Clark, 893 N.E.2d 462 (Ohio 2008). “R.C. 2967.01(E). *250 Accordingly, parole is neither a part of a maximum penalty nor a consequence of a guilty plea.”
Michael Stansell v., 828 F.3d 412 (6th Cir. 2016). “Ohio Rev. Code § 2967.01(N). As a few examples, the individual might have to undergo random drug testing, live in a halfway house, or maintain employment.”
State v. Bates (Slip Opinion), 2022 Ohio 475 (Ohio 2022). “{¶ 21} At its core, postrelease control is a sanction; it is an additional term of supervision after an offender’s release from prison that imposes certain restrictions on the offender and, if violated, it allows the APA to impose conditions and consequences, including prison…”
Woods v. Telb, 733 N.E.2d 1103 (Ohio 2000). “” R.C. 2967.01(0). Those sections do not deal with prison terms at all, which are dealt with in R.”
— Ohio Rev. Code § 2967.01(O) — 4 cases
State v. Joseph, 2010 Ohio 954 (Ohio 2010). “R.C. 2967.01(0) and 2947.23. If the state does not appeal an erroneous sentence within 30 days, it should not be allowed to turn back the clock, as if the sentence did not occur.”
Woods v. Telb, 2000 Ohio 171 (Ohio 2000).
State v. McHargue, 2024 Ohio 924 (Ohio Ct. App. 2024).
State v. Kamal, 2019 Ohio 3928 (Ohio Ct. App. 2019).
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