Ohio Revised Code

Ohio Rev. Code § 4511.201 (2026)

Operation off street or highway in willful or wanton disregard of the safety of persons or property

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(A) No person shall operate a vehicle, trackless trolley, or streetcar on any public or private property other than streets or highways, in willful or wanton disregard of the safety of persons or property.

This section does not apply to the competitive operation of vehicles on public or private property when the owner of such property knowingly permits such operation thereon.

(B) Except as otherwise provided in this division, whoever violates this section is guilty of a minor misdemeanor. If, within one year of the offense, the offender previously has been convicted of or pleaded guilty to one predicate motor vehicle or traffic offense, whoever violates this section is guilty of a misdemeanor of the fourth degree. If, within one year of the offense, the offender previously has been convicted of two or more predicate motor vehicle or traffic offenses, whoever violates this section is guilty of a misdemeanor of the third degree.

Notes of Decisions
Cited in 11 cases (1 in the last 5 years), 1968–2026 · leading case: City of Elyria v. Tress, 595 N.E.2d 1031 (Ohio Ct. App. 9th Dist. 1991).
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City of Elyria v. Tress, 595 N.E.2d 1031 (Ohio Ct. App. 9th Dist. 1991). “11, recklessly operated the van, R.C. 4511.201, and refused to dutifully stop and report an accident, R.”
Radecki v. Lammers, 238 N.E.2d 545 (Ohio 1968). · cites it 2× “Since the collision did not occur on “streets or highways,” reference to Section 4511.201 of the Revised Code is necessary to determine the standard of care required of *103 the defendant and the decedent.”
State v. Frank, 442 N.E.2d 469 (Ohio Ct. App. 1st Dist. 1981). “R.C. 4511.201. 3 The prohibition also serves to further the state’s interest in preventing damage to various forms of property.”
State v. Eaton, 2010-Ohio-6065. “19(A)(1)(a); reckless operation of a motor vehicle in violation of R.C. 4511.201; open container in a motor vehicle in -4- Case No.”
Jarrell v. Woodland Mfg. Co., 655 N.E.2d 1015 (Ohio Ct. App. 10th Dist. 1982). · cites it 2× “Bacause we believe the statutory test for negligence in this case is found in R.C. 4511.201, we will not discuss the extensive arguments of counsel regarding the application to this case of R.”
State v. Fraam, 2017-Ohio-1088. · cites it 7× “Fraam violated R.C. 4511.201, a third-degree misdemeanor as charged.”
Klyn v. Aruta, 517 N.E.2d 992 (Ohio Ct. App. 1986). “1 The court notes that appellee has relied upon R.C. 4511.201 which prohibits reckless operation of vehicles off streets and highways.”
Boyd, No. 5:25-cv-01544 (N.D. Ohio Apr. 24, 2026). “Newman recommended that Plaintiff be found guilty of violating Ohio Revised Code § 4511.201 because he “operated his vehicle in willful or wanton disregard for the safety of persons or property.”
State v. Spencer, 8 Ohio App. Unrep. 669 (Ohio Ct. App. 11th Dist. 1990). · cites it 2× “22(C) was inapplicable to R.C. 4511.201, which provided that no person shall operate a vehicle on a public, highway "without due regard for the safety of persons or property.”
State v. Tite, 959 N.E.2d 1105 (Ohio Ct. App. 6th Dist. 2011). “{¶ 20} Creation of a prima-facie showing of knowledge under R.C. 4511.201(B)(2) based upon the owner’s knowledge of charges against or convictions of an operator that would or could result in suspension or cancellation of driving privileges also requires proof that the operator…”
State v. Holzapfel, 2014-Ohio-955. “{¶ 4} Holzapfel was subsequently charged with one count of failure to maintain reasonable control, in violation of R.C. 4511.201(A), a minor misdemeanor; and two counts of OVI, in violation of R.”
Ohio Rev. Code § 4511.201(A): 2 cases
State v. Fraam, 2017-Ohio-1088. “Fraam violated R.C. 4511.201, a third-degree misdemeanor as charged.”
State v. Holzapfel, 2014-Ohio-955. “{¶ 4} Holzapfel was subsequently charged with one count of failure to maintain reasonable control, in violation of R.C. 4511.201(A), a minor misdemeanor; and two counts of OVI, in violation of R.”
Ohio Rev. Code § 4511.201(B): 1 case
State v. Fraam, 2017-Ohio-1088. “Fraam violated R.C. 4511.201, a third-degree misdemeanor as charged.”
Ohio Rev. Code § 4511.201(B)(2): 1 case
State v. Tite, 959 N.E.2d 1105 (Ohio Ct. App. 6th Dist. 2011). “{¶ 20} Creation of a prima-facie showing of knowledge under R.C. 4511.201(B)(2) based upon the owner’s knowledge of charges against or convictions of an operator that would or could result in suspension or cancellation of driving privileges also requires proof that the operator…”
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