Ohio Revised Code

Ohio Rev. Code § 3109.10 (2026)

Liability of parents for willful and malicious assaults by their children

✓ current as of May 2026
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As used in this section, "parent" has the same meaning as in section 3109.09 of the Revised Code.

Any person is entitled to maintain an action to recover compensatory damages in a civil action, in an amount not to exceed ten thousand dollars and costs of suit in a court of competent jurisdiction, from the parent of a child under the age of eighteen if the child willfully and maliciously assaults the person by a means or force likely to produce great bodily harm. A finding of willful and malicious assault by a means or force likely to produce great bodily harm is not dependent upon a prior finding that the child is a delinquent child.

Any action brought pursuant to this section shall be commenced and heard as in other civil actions for damages.

The monetary limitation upon compensatory damages set forth in this section does not apply to a civil action brought pursuant to section 2307.70 of the Revised Code.

Notes of Decisions
Cited in 13 cases (2 in the last 5 years), 1978–2024 · leading case: Cuervo v. Snell, 723 N.E.2d 139 (Ohio Ct. App. 1998).
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Cuervo v. Snell, 723 N.E.2d 139 (Ohio Ct. App. 1998). · cites it 5× “ey failed to move for relief from the default judgment, failed to present evidence at the damages *566 hearing, and failed to object to evidence submitted by plaintiffs at the damages hearing, (2) plaintiffs’ claims were barred by the applicable statute of limitations, and (3)…”
Labadie v. Semler, 585 N.E.2d 862 (Ohio Ct. App. 1990). · cites it 5× “Regina Labadie also alleged that Patricia and Robert Semler were civilly liable for the actions of their son William under R.C. 3109.10. In a March 27, 1989 judgment entry, the court found thatRegina Labadie had failed to show that William Semler had intentionally injured Regina…”
Thompson v. Park River Corp., 830 N.E.2d 1252 (Ohio Ct. App. 2005). · cites it 3× “In their motion to dismiss, Jihad and Joanne Rizkallah argued that, pursuant to R.C. 3109.10, they were liable as parents for the conduct of Andrew only if he had “willfully and maliciously” assaulted Eric “by a means or force *511 likely to produce great bodily harm.”
Steppe v. Kmart Stores, 737 N.E.2d 58 (Ohio Ct. App. 1999). “In counts one and two, Carolyn Steppe and Kimberly Valliere alleged sexual assault and battery and intentional/negligent infliction of emotion distress against defendant James Workman; in counts three and four, they alleged negligence and asserted a claim for liability under…”
Offhaus v. Guthrie, 746 N.E.2d 685 (Ohio Ct. App. 2000). · cites it 2× “The complaint alleged that the Hutmans were liable in damages under R.C. 3109.10 and the doctrines of negligent supervision and negligent entrustment.”
McGinnis v. Kinkaid, 437 N.E.2d 313 (Ohio Ct. App. 1981). · cites it 6× “4 Although R.C. 3109.10 establishes statutory parental liability for the assaults of their children, it is clear from the record that this action was instituted after the expiration of the statute of limitations applicable to a claim asserted under R.”
Blevins v. Hartman, 2013 Ohio 3297 (Ohio Ct. App. 2013). “{¶42} The court found that because Jeremy was an emancipated adult at the time he committed the murder, his parents were under no duty to Jessica because of their status as Jeremy’s parents.”
Gosnell v. Middlebrook, 563 N.E.2d 32 (Ohio Ct. App. 1988). · cites it 3× “The trial court found that the statutoiy liability of parents under R.C. 3109.10 is in derogation of common law, that the statute must be strictly construed, and that pursuant to the “plain meaning” thereof, defendant Ronald Lawhorn was entitled to summary judgment, which is…”
Liddy v. Smole, 381 N.E.2d 1335 (Ohio Ct. App. 1978). · cites it 2× “Section 3109.10, relating to assaults, provides: “Any person is entitled to maintain an action to recover compensatory damages in a civil action, in an amount not to exceed two thousand dollars and costs of suit in a court of competent jurisdiction, from the parents having the…”
Doe v. St. Edward High Sch. (N.D. Ohio 2022). · cites it 2× “Spencer, for parental liability under O.R.C. § 3109.10 (Counts 9 and 10) and spoliation of evidence (Count 14).”
A.W. v. Twinsburg Bd. of Edn., 2024 Ohio 2486 (Ohio Ct. App. 2024). “’s parents for assault, failure to exercise parental control in violation of R.C. 3109.10, and negligence. The complaint also alleged causes of action against the Board for recklessly failing to exercise control of a student, negligently failing to exercise control of a student,…”
White v. Mansfield-Richland, Morrow Counties Policy Commt. of Total Operation Against Poverty, Inc., 2013 Ohio 3296 (Ohio Ct. App. 2013). “{¶42} The court found that because Jeremy was an emancipated adult at the time he committed the murder, his parents were under no duty to Jessica because of their status as Jeremy’s parents.”
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