Ohio Revised Code

Ohio Rev. Code § 4123.95 (2026)

Liberal construction of chapter

✓ current as of May 2026
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Sections 4123.01 to 4123.94, inclusive, of the Revised Code shall be liberally construed in favor of employees and the dependents of deceased employees.

Notes of Decisions
Cited in 234 cases (17 in the last 5 years), 1961–2025 · leading case: Armstrong v. John R. Jurgensen Co., 2013 Ohio 2237 (Ohio 2013).
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Armstrong v. John R. Jurgensen Co., 2013 Ohio 2237 (Ohio 2013). · cites it 8× “Chrysler Corp., 92 Ohio St.3d 184, 189 , 749 N.E.”
Soloman v. Dayton Window & Door Co., L.L.C., 2011 Ohio 6182 (Ohio Ct. App. 2011). · cites it 14× “But Soloman contends that the phrase “same services” must be construed narrowly, citing R.C. 4123.95, which says that the workers’ compensation statutes “shall be liberally construed in favor of employees.”
Stivison v. Goodyear Tire & Rubber Co., 1997 Ohio 321 (Ohio 1997). · cites it 4× “01(C) sets forth the basic coverage requirement that, to be compensable, an injury must be “received in the course of, and arising out of, the injured employee’s employment.”
Swallow v. Indus. Comm'n, 521 N.E.2d 778 (Ohio 1988). · cites it 4× “He states that it is to his advantage to have each of the awards paid concurrently, so that he would receive two separate awards for the loss of each arm paid over two hundred twenty-five weeks and two separate payments for loss of both legs paid over two hundred weeks.”
State ex rel. Ohio Presbyterian Ret. Servs., Inc. v. Indus. Comm. (Slip Opinion), 2017 Ohio 7577 (Ohio 2017). · cites it 3× “Having granted reconsideration of that decision, we now turn to the propositions of law presented in OPRS’s direct appeal: (1) “R.C. 4123.95’s requirement of liberal construction in favor of employees does not allow a court to read into a statute something that cannot reasonably…”
Kilgore v. Chrysler Corp., 92 Ohio St. 3d 184 (Ohio 2001). · cites it 3× “*186 Law and Analysis The overarching consideration in this case is the requirement imposed by R.C. 4123.95 that workers’ compensation statutes are to be “liberally construed in favor of employees.”
Starkey v. Builders FirstSource Ohio Valley, L.L.C., 2011 Ohio 3278 (Ohio 2011). · cites it 4× “R.C. 4123.95. The ultimate question in a workers’ compensation appeal is the claimant’s right to participate in the fund for an injury received in the course of, and arising out of, the claimant’s employment.”
Thomas v. Logue, Admr. of Ohio Bur. of Workers' Comp., 2022 Ohio 1603 (Ohio Ct. App. 2022). · cites it 3× “If the statute in question " 'is silent or ambiguous with respect to the specific issue, the question 4 We note that R.C. 4123.95 provides: "Sections 4123.01 to 4123.”
Littlefield v. Pillsbury Co., 453 N.E.2d 570 (Ohio 1983). · cites it 3× “That is, an employee will be entitled to workers’ compensation benefits when the employment creates a special hazard and the injuries are sustained because of that hazard.”
Ruckman v. Cubby Drilling, Inc., 689 N.E.2d 917 (Ohio 1998). · cites it 2× “” Cubby discounts both of these statutory considerations. Under Cubby’s interpretation, the statute would strip employees of their statutory right to participate in the Workers’ Compensation Fund solely on the basis of their participation in ridesharing, an activity that the…”
Valentine v. PPG Indus., Inc., 821 N.E.2d 580 (Ohio Ct. App. 2004). · cites it 2× “R.C. 4123.95; Bailey v. Republic Engineered Steels, Inc.”
MTD Prods., Inc. v. Robatin, 572 N.E.2d 661 (Ohio 1991). · cites it 2× “R.C. 4123.95. As a general rule, an employee with a fixed place of employment, who is injured while traveling to or from his place of employment, is not entitled to participate in the Workers’ Compensation Fund because the requisite causal connection between the injury and the…”
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— Ohio Rev. Code § 4123.95(D) — 1 case
State ex rel. McDonald v. Indus. Comm., 2023 Ohio 1620 (Ohio 2023).
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