Ohio Revised Code

Ohio Rev. Code § 5321.12 (2026)

Recovery of damages

✓ current as of May 2026
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In any action under Chapter 5321. of the Revised Code, any party may recover damages for the breach of contract or the breach of any duty that is imposed by law.

Notes of Decisions
Cited in 16 cases (3 in the last 5 years), 1983–2026 · leading case: Mann v. Northgate Investors, L.L.C., 2014-Ohio-455, 5 N.E.3d 594.
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Mann v. Northgate Investors, L.L.C., 2014-Ohio-455, 5 N.E.3d 594. · cites it 2× “R.C. 5321.12 states: “In any action under Chapter 5321.”
Shump v. First Cont'l-Robinwood Assocs., 644 N.E.2d 291 (Ohio 1994). “R.C. 5321.12 states: “In any action under Chapter 5321.”
Vlcek v. Brogee, 2013-Ohio-4250. · cites it 4× “” They stated that any damage was caused by the tenants and that Vlcek could recover damages from the tenants under R.C. 5321.12. Citing Sherwin v. Cabana Club Apartments, 70 Ohio App.”
Sherman v. Pearson, 673 N.E.2d 643 (Ohio Ct. App. 1st Dist. 1996). · cites it 2× “” Under R.C. 5321.12, a party has a statutory remedy for damages for the breach of any duty imposed under the Act.”
Aetna Cas. & Sur. Co. v. Neff, 30 F. Supp. 2d 990 (S.D. Ohio 1998). · cites it 6× “Ohio Rev.Code § 5321.12 allows for additional remedies other than those provided in the statutory framework; 5 “the remedies in R.”
Shump v. First Cont'l-Robinwood Assoc., 71 Ohio St. 3d 414 (Ohio 1994). “12 states, "In any action under Chapter 5321 of the Revised Code, any party may recover damages for the breach of contract or the breach of any duty that is imposed by law.”
Chase v. Theodore Mayer Bros., 592 F. Supp. 90 (S.D. Ohio 1983). · cites it 2× “See Ohio Rev.Code § 5321.12. This does not mean that state law cannot be adopted as the federal rule of decision in instances where it is compatible with the federal statutory and regulatory scheme.”
Spinner v. Barger, 2017-Ohio-1489. “{¶16} R.C. 5321.12 provides that ‘[i]n any action under Chapter 5321.”
Lloyd v. Roosevelt Props., Ltd., 2018-Ohio-3163. “{¶53} Therefore, where a landlord breaches a promise to make repairs to the leased premises and the tenant does not make the repairs themselves, the proper measure of damages is the difference between the rental value of the property in its defective condition, and what the…”
Allen v. Lee, 538 N.E.2d 1073 (Ohio Ct. App. 8th Dist. 1987). “R.C. 5321.12. The tenant’s contract damages here include her expenditures in reliance on the landlord’s promises.”
Bierl v. BGZ Assoc. II, L.L.C., 2013-Ohio-648. · cites it 2× “R.C. 5321.12 provides that “[i]n any action under Chapter 5321.”
KGM Capital, L.L.C. v. Jackson, 2014-Ohio-2427. “” R.C. 5321.12 provides that “[i]n any action under Chapter 5321 of the Revised Code, any party may recover damages for the breach of contract or the breach of any duty that is imposed by law.”
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