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Ohio Revised Code

Ohio Rev. Code § 2967.15 (2026)

Violating condition of conditional pardon, parole, other form of authorized release, transitional control, or post-release control

✓ current as of May 2026
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Effective:
April 9, 2009
Latest Legislation:
House Bill 130 - 127th General Assembly
PDF:
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(A) If an adult parole authority field officer has reasonable cause to believe that a person who is a parolee or releasee, who is under transitional control, or who is under another form of authorized release and who is under the supervision of the adult parole authority has violated or is violating the condition of a conditional pardon, parole, other form of authorized release, transitional control, or post-release control specified in division (A) of section 2967.131 of the Revised Code or any other term or condition of the person's conditional pardon, parole, other form of authorized release, transitional control, or post-release control, the field officer may arrest the person without a warrant or order a peace officer to arrest the person without a warrant. A person so arrested shall be confined in the jail of the county in which the person is arrested or in another facility designated by the chief of the adult parole authority until a determination is made regarding the person's release status. Upon making an arrest under this section, the arresting or supervising adult parole authority field officer promptly shall notify the superintendent of parole supervision or the superintendent's designee, in writing, that the person has been arrested and is in custody and submit an appropriate report of the reason for the arrest.

(B) Except as otherwise provided in this division, prior to the revocation by the adult parole authority of a person's pardon, parole, or other release and prior to the imposition by the parole board or adult parole authority of a new prison term as a post-release control sanction for a person, the adult parole authority shall grant the person a hearing in accordance with rules adopted by the department of rehabilitation and correction under Chapter 119. of the Revised Code. The adult parole authority is not required to grant the person a hearing if the person is convicted of or pleads guilty to an offense that the person committed while released on a pardon, on parole, or another form of release, or on post-release control and upon which the revocation of the person's pardon, parole, other release, or post-release control is based.

If a person who has been pardoned is found to be a violator of the conditions of the parolee's conditional pardon or commutation of sentence, the authority forthwith shall transmit to the governor its recommendation concerning that violation, and the violator shall be retained in custody until the governor issues an order concerning that violation.

If the authority fails to make a determination of the case of a parolee or releasee alleged to be a violator of the terms and conditions of the parolee's or releasee's conditional pardon, parole, other release, or post-release control sanctions within a reasonable time, the parolee or releasee shall be released from custody under the same terms and conditions of the parolee's or releasee's original conditional pardon, parole, other release, or post-release control sanctions.

(C)(1) If a person who is a parolee or releasee, who is under transitional control, or who is under another form of authorized release under the supervision of the adult parole authority absconds from supervision, the supervising adult parole authority field officer shall report that fact to the superintendent of parole supervision, in writing, and the authority shall declare that person to be a violator at large. Upon being advised of the apprehension and availability for return of a violator at large, the superintendent of parole supervision shall determine whether the violator at large should be restored to parole, transitional control, another form of authorized release, or post-release control.

The time between the date on which a person who is a parolee or other releasee is declared to be a violator or violator at large and the date on which that person is returned to custody in this state under the immediate control of the adult parole authority shall not be counted as time served under the sentence imposed on that person or as a part of the term of post-release control.

(2) A person who is under transitional control or who is under any form of authorized release under the supervision of the adult parole authority is considered to be in custody while under the transitional control or on release, and, if the person absconds from supervision, the person may be prosecuted for the offense of escape.

(D) A person who is a parolee or releasee, who is under transitional control, or who is under another form of authorized release under the supervision of the adult parole authority and who has violated a term or condition of the person's conditional pardon, parole, transitional control, other form of authorized release, or post-release control shall be declared to be a violator if the person is committed to a correctional institution outside the state to serve a sentence imposed upon the person by a federal court or a court of another state or if the person otherwise leaves the state.

(E) As used in this section, "peace officer" has the same meaning as in section 2935.01 of the Revised Code.
Notes of Decisions
Cited in 84 cases (24 in the last 5 years), 1968–2025 · leading case: State v. Delvallie, 2022 Ohio 470 (Ohio Ct. App. 2022).
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State v. Delvallie, 2022 Ohio 470 (Ohio Ct. App. 2022). · cites it 11× “It is important to recognize that the indefinite prison sentence with the executive branch’s review has been a mainstay of Ohio law since time immemorial, and it does not appear that any argument as to the constitutional validity of the Reagan Tokes Law challenges R.C. 2929.144…”
State v. Conyers, 87 Ohio St. 3d 246 (Ohio 1999). · cites it 20× “A conflict then arose because the language of former R.C. 2967.15(C)(2), which, at the relevant times, provided that “[a] furloughee or releasee other than a person who is released on parole * * * is considered to be in custody * * * and * * * may be prosecuted for the offense…”
State v. Thompson, 514 N.E.2d 407 (Ohio 1987). · cites it 5× “R.C. 2967.15 provides the procedure by which a parole officer may effect the arrest of a parolee.”
State v. Thompson, 809 N.E.2d 1134 (Ohio 2004). · cites it 8× “021 and held that it limited the application of the 1998 version of R.C. 2967.15 to offenders whose underlying offenses were committed after July 1,1996.”
State ex rel. Taylor v. Ohio Adult Parole Auth., 609 N.E.2d 546 (Ohio 1993). · cites it 12× “Moreover, to the extent that Taylor was also charged with technical parole violations, the final parole revocation hearing was held within sixty days after he was taken into custody pursuant to the detainer, as explained in Part II.”
State v. Conyers, 1999 Ohio 60 (Ohio 1999). · cites it 24× “34(A)(1) to parolee—During period of October 4, 1996 to March 17, 1998, the parolee-exclusion language contained in the special provision of former R.C. 2967.15(C)(2) prevailed as an exception to the general provision of R.”
State ex rel. Marsh v. Tibbals (Slip Opinion), 2017 Ohio 829 (Ohio 2017). · cites it 4× ““Neither due process of law nor R.C. 2967.15’s or former Ohio Adm.Code 5120:l-l-19(A)’s ‘reasonable time’ requirement compels a final revocation parole hearing while an alleged parole violator is imprisoned pending prosecution for, or after conviction of, another crime.”
State v. Rue (Slip Opinion), 2020 Ohio 6706 (Ohio 2020). · cites it 3× “{¶ 43} The attorney general next directs our attention to R.C. 2967.15(C)(1), which states that the adult parole authority supervising a parolee or releasee who absconds from supervision “shall declare that person to be a violator at large” and the time between that declaration…”
State ex rel. Wright v. Ohio Adult Parole Auth., 661 N.E.2d 728 (Ohio 1996). · cites it 3× “two “claims for relief’: (1) the APA failed to give him a final parole hearing within a reasonable *86 time, in violation of R.C. 2967.15(A), and (2) the APA erroneously relied on the evidence obtained by Fisher and the police in their illegal searches of his residence in the…”
Wilson v. State, 655 N.E.2d 1348 (Ohio Ct. App. 1995). · cites it 5× “See R.C. 2967.15. The appellant filed the case below on October 4, 1993, seeking a declaratory judgment that the lack of an opportunity for bail in connection -with parole revocation proceedings violated his rights under the Eighth Amendment to the United States Constitution,…”
Williams v. Morris, 584 N.E.2d 671 (Ohio 1992). · cites it 13× “I Specificity of the Order R.C. 2967.15 states in part: “In the event the [adult parole] authority fails to make a determination of the case of a parolee alleged to be a violator of the conditions of his pardon or parole within a reasonable time such parolee shall be released…”
State ex rel. Gillen v. Ohio Adult Parole Auth., 650 N.E.2d 454 (Ohio 1995). · cites it 5× “Former R.C. 2967.15 provided in part that if a parolee is declared a parole violator, “the time from the date of the declared violation of his * * * parole to the date he becomes available for return to the institution shall not be counted as a part of the time or sentence…”
Show all 84 citing cases →
— Ohio Rev. Code § 2967.15(A) — 4 cases
State ex rel. Wright v. Ohio Adult Parole Auth., 661 N.E.2d 728 (Ohio 1996). “two “claims for relief’: (1) the APA failed to give him a final parole hearing within a reasonable *86 time, in violation of R.C. 2967.15(A), and (2) the APA erroneously relied on the evidence obtained by Fisher and the police in their illegal searches of his residence in the…”
State v. Harrison, 2022 Ohio 741 (Ohio Ct. App. 2022).
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 § 2967.15(B) — 9 cases
State v. Delvallie, 2022 Ohio 470 (Ohio Ct. App. 2022). “It is important to recognize that the indefinite prison sentence with the executive branch’s review has been a mainstay of Ohio law since time immemorial, and it does not appear that any argument as to the constitutional validity of the Reagan Tokes Law challenges R.C. 2929.144…”
State v. Sealey, 2021 Ohio 1949 (Ohio Ct. App. 2021).
State ex rel. Anderson v. Chambers-Smith, 2022 Ohio 2844 (Ohio 2022).
Kellogg v. Shoemaker, 927 F. Supp. 244 (S.D. Ohio 1996).
Alford v. Crutchfield, 2016 Ohio 7295 (Ohio Ct. App. 2016).
— Ohio Rev. Code § 2967.15(C) — 4 cases
Reed v. State Ex Rel. Ortiz, 947 P.2d 86 (N.M. 1997).
State v. Bell, 2016 Ohio 4630 (Ohio Ct. App. 2016).
Chapin v. Bradley, 2016 Ohio 7441 (Ohio Ct. App. 2016).
Smith v. Buchanan, 2020 Ohio 3886 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2967.15(C)(1) — 15 cases
State v. Rue (Slip Opinion), 2020 Ohio 6706 (Ohio 2020). “{¶ 43} The attorney general next directs our attention to R.C. 2967.15(C)(1), which states that the adult parole authority supervising a parolee or releasee who absconds from supervision “shall declare that person to be a violator at large” and the time between that declaration…”
State ex rel. Marsh v. Tibbals (Slip Opinion), 2017 Ohio 829 (Ohio 2017). ““Neither due process of law nor R.C. 2967.15’s or former Ohio Adm.Code 5120:l-l-19(A)’s ‘reasonable time’ requirement compels a final revocation parole hearing while an alleged parole violator is imprisoned pending prosecution for, or after conviction of, another crime.”
State v. Martello, 780 N.E.2d 250 (Ohio 2002).
State v. Martello, 2002 Ohio 6661 (Ohio 2002).
Chapin v. Bradley, 2016 Ohio 7441 (Ohio Ct. App. 2016).
— Ohio Rev. Code § 2967.15(C)(2) — 7 cases
State v. Conyers, 87 Ohio St. 3d 246 (Ohio 1999). “A conflict then arose because the language of former R.C. 2967.15(C)(2), which, at the relevant times, provided that “[a] furloughee or releasee other than a person who is released on parole * * * is considered to be in custody * * * and * * * may be prosecuted for the offense…”
State v. Thompson, 809 N.E.2d 1134 (Ohio 2004). “021 and held that it limited the application of the 1998 version of R.C. 2967.15 to offenders whose underlying offenses were committed after July 1,1996.”
State v. Conyers, 1999 Ohio 60 (Ohio 1999). “34(A)(1) to parolee—During period of October 4, 1996 to March 17, 1998, the parolee-exclusion language contained in the special provision of former R.C. 2967.15(C)(2) prevailed as an exception to the general provision of R.”
Riffle v. Physicians & Surgeons Ambulance Serv., 2011 Ohio 6595 (Ohio Ct. App. 2011).
State v. Chandler, 2016 Ohio 1017 (Ohio Ct. App. 2016).
— Ohio Rev. Code § 2967.15(D) — 2 cases
State ex rel. Marsh v. Tibbals (Slip Opinion), 2017 Ohio 829 (Ohio 2017). ““Neither due process of law nor R.C. 2967.15’s or former Ohio Adm.Code 5120:l-l-19(A)’s ‘reasonable time’ requirement compels a final revocation parole hearing while an alleged parole violator is imprisoned pending prosecution for, or after conviction of, another crime.”
Dugas v. Ohio Adult Parole Auth., 2022 Ohio 1923 (Ohio Ct. App. 2022).
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