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Ohio Revised Code

Ohio Rev. Code § 2967.131 (2026)

Conditions of post-release control

✓ current as of May 2026
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Effective:
October 3, 2023
Latest Legislation:
House Bill 33 - 135th General Assembly
PDF:
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(A) In addition to any other terms and conditions of a conditional pardon or parole, of transitional control, or of another form of authorized release from confinement in a state correctional institution that is granted to an individual and that involves the placement of the individual under the supervision of the adult parole authority, and in addition to any other sanctions of post-release control of a felon imposed under section 2967.28 of the Revised Code, the authority or, in the case of a conditional pardon, the governor shall include in the terms and conditions of the conditional pardon, parole, transitional control, or other form of authorized release or shall include as conditions of the post-release control the conditions that the individual or felon not leave the state without permission of the court or the individual's or felon's parole or probation officer and that the individual or felon abide by the law during the period of the individual's or felon's conditional pardon, parole, transitional control, other form of authorized release, or post-release control.

(B)(1) The department of rehabilitation and correction, as a condition of parole or post-release control, may require that the individual or felon shall not ingest or be injected with a drug of abuse and shall submit to random drug testing as provided in divisions (B)(2), (3), and (4) of this section and that the results of the drug test indicate that the individual or felon did not ingest or was not injected with a drug of abuse.

(2) If the adult parole authority has general control and supervision of an individual or felon who is required to submit to random drug testing as a condition of parole or post-release control under division (B)(1) of this section, the authority may cause the individual or felon to submit to random drug testing performed by a laboratory or entity that has entered into a contract with any of the governmental entities or officers authorized to enter into a contract with that laboratory or entity under section 341.26, 753.33, or 5120.63 of the Revised Code.

(3) If no laboratory or entity described in division (B)(2) of this section has entered into a contract as specified in that division, the adult parole authority shall cause the individual or felon to submit to random drug testing performed by a reputable public laboratory to determine whether the individual or felon who is the subject of the drug test ingested or was injected with a drug of abuse.

(4) If a laboratory or entity has entered into a contract with a governmental entity or officer as specified in division (B)(2) of this section, the laboratory or entity shall perform the random drug testing under division (B)(2) of this section in accordance with the applicable standards that are included in the terms of that contract. A public laboratory shall perform the random drug tests under division (B)(3) of this section in accordance with the standards set forth in the policies and procedures established by the department of rehabilitation and correction pursuant to section 5120.63 of the Revised Code. An individual or felon who is required under division (B)(1) of this section to submit to random drug testing as a condition of parole or post-release control and whose test results indicate that the individual or felon ingested or was injected with a drug of abuse shall pay the fee for the drug test if the adult parole authority requires payment of a fee. A laboratory or entity that performs the random drug testing on a parolee or releasee under division (B)(2) or (3) of this section shall transmit the results of the drug test to the adult parole authority.

(C)(1) During the period of a conditional pardon or parole, of transitional control, or of another form of authorized release from confinement in a state correctional institution that is granted to an individual and that involves the placement of the individual under the supervision of the adult parole authority, and during a period of post-release control of a felon imposed under section 2967.28 of the Revised Code, authorized field officers of the authority who are engaged within the scope of their supervisory duties or responsibilities may search, with or without a warrant, the person of the individual or felon, the place of residence of the individual or felon, and a motor vehicle, another item of tangible or intangible personal property, or other real property in which the individual or felon has a right, title, or interest or for which the individual or felon has the express or implied permission of a person with a right, title, or interest to use, occupy, or possess, if any of the following apply:

(a) The field officers have reasonable grounds to believe that the individual or felon has left the state, is not abiding by the law, or otherwise is not complying with the terms and conditions of the individual's or felon's conditional pardon, parole, transitional control, other form of authorized release, or post-release control.

(b) The adult parole authority requires the individual's or felon's consent to searches as part of the terms and conditions of the conditional pardon or parole, of the transitional control, of the other form of authorized release from confinement in a state correctional institution that is granted to a person, or of the post-release control and that involves the placement of the person under the supervision of the adult parole authority, and the individual or felon agreed to those terms and conditions, provided that this division applies with respect to an individual only if the individual is a felon.

(c) The individual or felon otherwise provides consent for the search, provided that this division applies with respect to an individual only if the individual is a felon.

(2) The adult parole authority shall provide each individual who is granted a conditional pardon or parole, transitional control, or another form of authorized release from confinement in a state correctional institution and each felon who is under post-release control with a written notice that informs the individual or felon that authorized field officers of the authority who are engaged within the scope of their supervisory duties or responsibilities may conduct the types of searches described in division (C)(1) of this section during the period of the conditional pardon, parole, transitional control, other form of authorized release, or post-release control if any of the following apply:

(a) The field officers have reasonable grounds to believe that the individual or felon has left the state, is not abiding by the law, or otherwise is not complying with the terms and conditions of the individual's or felon's conditional pardon, parole, transitional control, other form of authorized release, or post-release control.

(b) The adult parole authority requires the individual's or felon's consent to searches as part of the terms and conditions of the conditional pardon or parole, of transitional control, of the other form of authorized release from confinement in a state correctional institution that is granted to a person, or of the post-release control and that involves the placement of the person under the supervision of the adult parole authority, and the individual or felon agreed to those terms and conditions, provided that this division applies with respect to an individual only if the individual is a felon.

(c) The individual or felon otherwise provides consent for the search, provided that this division applies with respect to an individual only if the individual is a felon.

Last updated August 28, 2023 at 1:20 PM

Notes of Decisions
Cited in 85 cases (24 in the last 5 years), 1998–2026 · leading case: State v. Gordon (Slip Opinion), 2018 Ohio 1975 (Ohio 2018).
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State v. Gordon (Slip Opinion), 2018 Ohio 1975 (Ohio 2018). · cites it 4× “19(B)(2)(e) provides that a trial court shall [n]otify the offender that, if a period of supervision is imposed following the offender's release from prison, as described in division (B)(2)(c) or (d) of this section, and if the offender violates that supervision or a condition…”
State v. McCain, 797 N.E.2d 527 (Ohio Ct. App. 2003). · cites it 8× “131 of the Revised Code, Officers of the Adult Parole Authority may conduct warrantless searches of your person, your place of residence, your personal property, or any property which you have been given permission to use *384 if they have reasonable grounds to believe that you…”
United States v. Ronald Sharp, 40 F.4th 749 (6th Cir. 2022). · cites it 3× “Ohio Rev. Code § 2967.131(C). On September 24, 2019, a woman complained to local police that, ten days earlier, Sharp had sexually assaulted her at his house while her two children slept in a nearby room.”
State Banks, 2015 Ohio 5372 (Ohio Ct. App. 2015). · cites it 3× “) In addition, Banks' plea form indicated that Banks understood that three years of mandatory post-release control would be imposed and explained: I understand that a violation of post-release control conditions or the condition under R.C. 2967.131 could result in more…”
State v. Demangone, 2023 Ohio 2522 (Ohio Ct. App. 2023). · cites it 2× “* * * (f) Notify the offender that, if a period of supervision is imposed following the offender's release from prison, as described in division (B)(2)(d) or (e) of this section, and if the offender violates that supervision or a condition of post-release control imposed under…”
State v. Benton, 695 N.E.2d 757 (Ohio 1998). · cites it 2× “After the defendant signed the Conditions of Supervision form, but while he was on parole and before the search in question was conducted, the General Assembly enacted R.C. 2967.131(B). 146 Ohio Laws, Part I, 125.”
State v. Nicholson, 2016 Ohio 50 (Ohio Ct. App. 2016). · cites it 2× “If a court imposes a sentence including a prison term on or after July 11, 2006, the failure of a court to notify the offender pursuant to division (B)(2)(e) of this section that the parole board may impose a prison term as described in division (B)(2)(e) of this section for a…”
United States v. Antonio R. Henry, 429 F.3d 603 (6th Cir. 2005). “3d at 521 (quoting Ohio Rev. Code Ann. § 2967.131 (C)) (second omission in original).”
State v. Newsome, 2012 Ohio 6119 (Ohio Ct. App. 2012). · cites it 2× “] *** (e) Notify the offender that, if a period of supervision is imposed following the offender’s release from prison, as described in division (B)(2)(c) or (d) of this section, and if the offender violates that supervision or a condition of post-release control imposed under…”
State v. Singleton, 2009 Ohio 6434 (Ohio 2009). · cites it 20× “19 of the Revised Code, and if the offender violates that supervision or a condition of post-release control imposed under division (B) of section 2967.131 of the Revised Code the parole board may impose as part of the sentence a prison term of up to one-half of the stated…”
State v. Jackson, 2012 Ohio 5548 (Ohio Ct. App. 2012). · cites it 3× “2012-CA-20 14 express or implied permission of a person with a right, title or interest to use, occupy, or possess, if the field officer has reasonable grounds to believe that the individual * * *is not abiding by the law, or is not complying with the terms and conditions of the…”
State v. Brown, 2016 Ohio 5893 (Ohio Ct. App. 2016). · cites it 2× “If a court imposes a sentence including a prison term on or after July 11, 2006, the failure of a court to notify the offender pursuant to division (B)(3)(e) of this section that the parole board may impose a prison term as described in division (B)(3)(e) of this section for a…”
Show all 85 citing cases →
— Ohio Rev. Code § 2967.131(A) — 3 cases
Swart v. Ohio Dep't of Rehab. & Corr., 728 N.E.2d 428 (Ohio Ct. App. 1999).
State v. Hendon, 2018 Ohio 1284 (Ohio Ct. App. 2018).
Tokes v. Dept. of Rehab. & Corr., 2018 Ohio 4149 (Ohio Ct. Cl. 2018).
— Ohio Rev. Code § 2967.131(B) — 19 cases
State v. Benton, 695 N.E.2d 757 (Ohio 1998). “After the defendant signed the Conditions of Supervision form, but while he was on parole and before the search in question was conducted, the General Assembly enacted R.C. 2967.131(B). 146 Ohio Laws, Part I, 125.”
State v. Bates, 2020 Ohio 267 (Ohio Ct. App. 2020).
State v. Nascembeni, 2022 Ohio 1662 (Ohio Ct. App. 2022).
State v. Goines, 2017 Ohio 8172 (Ohio Ct. App. 2017).
State v. Chasteen, 2013 Ohio 3573 (Ohio Ct. App. 2013).
— Ohio Rev. Code § 2967.131(C) — 22 cases
United States v. Ronald Sharp, 40 F.4th 749 (6th Cir. 2022). “Ohio Rev. Code § 2967.131(C). On September 24, 2019, a woman complained to local police that, ten days earlier, Sharp had sexually assaulted her at his house while her two children slept in a nearby room.”
State v. Jackson, 2012 Ohio 5548 (Ohio Ct. App. 2012). “2012-CA-20 14 express or implied permission of a person with a right, title or interest to use, occupy, or possess, if the field officer has reasonable grounds to believe that the individual * * *is not abiding by the law, or is not complying with the terms and conditions of the…”
State v. Karns, 2011 Ohio 6109 (Ohio Ct. App. 2011).
State v. Johnson, 2014 Ohio 5400 (Ohio Ct. App. 2014).
State v. Earns, 196 Ohio App. 3d 731 (Ohio Ct. App. 2011).
— Ohio Rev. Code § 2967.131(C)(1) — 3 cases
State v. Robinson, 2025 Ohio 2216 (Ohio Ct. App. 2025).
State v. Jenkins, 2025 Ohio 4447 (Ohio Ct. App. 2025).
State v. Harrison, 2024 Ohio 884 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2967.131(C)(1)(a) — 1 case
State v. Jenkins, 2025 Ohio 4447 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2967.131(C)(2) — 1 case
State v. Harrison, 2024 Ohio 884 (Ohio Ct. App. 2024).
— Ohio Rev. Code § 2967.131(b) — 1 case
State v. Freeman, 2014 Ohio 1732 (Ohio Ct. App. 2014).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.