Ohio Revised Code

Ohio Rev. Code § 5321.15 (2026)

Acts of landlord prohibited if residential property involved

✓ current as of May 2026
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(A) No landlord of residential premises shall initiate any act, including termination of utilities or services, exclusion from the premises, or threat of any unlawful act, against a tenant, or a tenant whose right to possession has terminated, for the purpose of recovering possession of residential premises, other than as provided in Chapters 1923., 5303., and 5321. of the Revised Code.

(B) No landlord of residential premises shall seize the furnishings or possessions of a tenant, or of a tenant whose right to possession has terminated, for the purpose of recovering rent payments, other than in accordance with an order issued by a court of competent jurisdiction.

(C) A landlord who violates this section is liable in a civil action for all damages caused to a tenant, or to a tenant whose right to possession has terminated, together with reasonable attorneys fees.

Notes of Decisions
Cited in 42 cases (9 in the last 5 years), 1980–2026 · leading case: Risch v. Samuel, 2020 Ohio 1094 (Ohio Ct. App. 2020).
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Risch v. Samuel, 2020 Ohio 1094 (Ohio Ct. App. 2020). · cites it 18× “15(C) and by failing to take evidence on the hours of her attorney’s service necessitated by Risch’s violation of R.C. 5321.15(A). Samuel contends that the court denied her statutory attorney fees upon its determination that Risch had not violated R.”
Geoffrey M. Radvansky v. City of Olmsted Falls, 395 F.3d 291 (6th Cir. 2005). · cites it 2× “Ohio Rev.Code Ann. § 5321.15. Caine suggested that if Rosemark did indeed change the locks, he should inform Radvansky not to break into the house.”
Staley v. Phillips, 2022 Ohio 2112 (Ohio Ct. App. 2022). · cites it 19× “R.C. 5321.15 expressly prohibits ‘self-help,’ wherein a landlord attempts to evict a residential tenant without resort to legal procedure.”
Brian Midkiff Monica Midkiff v. Adams Cnty. Reg'l Water Dist., 409 F.3d 758 (6th Cir. 2005). · cites it 2× “” Ohio Rev. Code Ann. § 5321.15 (A) provides that a landlord shall not “initiate any act, including termination of utilities or services, .”
Thomas v. Papadelis, 476 N.E.2d 726 (Ohio Ct. App. 1984). · cites it 8× “It was an attempt to waive the restrictions imposed on Papadelis, as a landlord, under R.C. 5321.15, for recovery of the premises.”
Crenshaw v. Rowland, 965 N.E.2d 341 (Ohio Ct. App. 2011). · cites it 17× “28 for past-due rent and for damage to the carpet, the court further found that appellee had breached her duties as a landlord in causing water services to be terminated and that her actions violated R.C. 5321.15. The court, therefore, found that defendants were entitled to…”
Mercer v. Halmbacher, 2015 Ohio 4167 (Ohio Ct. App. 2015). · cites it 2× “R.C. 5321.15(A) provides that landlords may only evict residential tenants by following the procedures set forth in R.”
Gaitawe v. Mays, 2012 Ohio 4749 (Ohio Ct. App. 2012). · cites it 11× “{¶ 7} Mays’s first assignment of error: “THE TRIAL COURT ERRED AS A MATTER OF LAW WHEN IT FAILED TO AWARD DEFENDANT-APPELLANT ATTORNEY FEES WHEN THE TRIAL COURT FOUND THAT THE PLAINTIFF-APPELLEE PROCEEDED WITH AN ILLEGAL EVICTION AGAINST DEFENDANT-APPELLANT IN VIOLATION OF R.C.…”
Jackson v. Brown, 614 N.E.2d 847 (Ohio Ct. App. 1992). · cites it 7× “Brown counterclaimed for compensation for violation of R.C. 5321.15, which states: “(A) No landlord of residential premises shall initiate any act, including termination of utilities or services, exclusion from the premises, or threat of any unlawful act, against a tenant, or a…”
Meacham v. Miller, 606 N.E.2d 996 (Ohio Ct. App. 1992). · cites it 4× “) *42 The Drake court commented in fn. 1 that the act permits courts to award attorney fees to tenants for a landlord’s retaliatory conduct (R.”
Germadnik v. Auld, 2018 Ohio 2889 (Ohio Ct. App. 2018). · cites it 2× “Germadnik “egregiously violated all of the prohibitions of R.C. 5321.15(A) by not only terminating the electric service but also locking [Ms.”
Amba Invests. v. Clark, 2022 Ohio 43 (Ohio Ct. App. 2022). · cites it 4× “2: {¶29} THE MAGISTRATE ERRED IN RULING THE EVICTION WAS NOT UNLAWFUL (O.R.C. §5321.15). 5. Clark did not request in his counterclaim's prayer for relief that the court require Amba to provide the itemized statement to him.”
Show all 42 citing cases →
— Ohio Rev. Code § 5321.15(15) — 1 case
Lee v. Wallace, 926 N.E.2d 328 (Ohio Ct. App. 2010).
— Ohio Rev. Code § 5321.15(A) — 22 cases
Risch v. Samuel, 2020 Ohio 1094 (Ohio Ct. App. 2020). “15(C) and by failing to take evidence on the hours of her attorney’s service necessitated by Risch’s violation of R.C. 5321.15(A). Samuel contends that the court denied her statutory attorney fees upon its determination that Risch had not violated R.”
Staley v. Phillips, 2022 Ohio 2112 (Ohio Ct. App. 2022). “R.C. 5321.15 expressly prohibits ‘self-help,’ wherein a landlord attempts to evict a residential tenant without resort to legal procedure.”
Geoffrey M. Radvansky v. City of Olmsted Falls, 395 F.3d 291 (6th Cir. 2005). “Ohio Rev.Code Ann. § 5321.15. Caine suggested that if Rosemark did indeed change the locks, he should inform Radvansky not to break into the house.”
Thomas v. Papadelis, 476 N.E.2d 726 (Ohio Ct. App. 1984). “It was an attempt to waive the restrictions imposed on Papadelis, as a landlord, under R.C. 5321.15, for recovery of the premises.”
Mercer v. Halmbacher, 2015 Ohio 4167 (Ohio Ct. App. 2015). “R.C. 5321.15(A) provides that landlords may only evict residential tenants by following the procedures set forth in R.”
— Ohio Rev. Code § 5321.15(B) — 4 cases
Risch v. Samuel, 2020 Ohio 1094 (Ohio Ct. App. 2020). “15(C) and by failing to take evidence on the hours of her attorney’s service necessitated by Risch’s violation of R.C. 5321.15(A). Samuel contends that the court denied her statutory attorney fees upon its determination that Risch had not violated R.”
Mercer v. Halmbacher, 2015 Ohio 4167 (Ohio Ct. App. 2015). “R.C. 5321.15(A) provides that landlords may only evict residential tenants by following the procedures set forth in R.”
Crenshaw v. Rowland, 965 N.E.2d 341 (Ohio Ct. App. 2011). “28 for past-due rent and for damage to the carpet, the court further found that appellee had breached her duties as a landlord in causing water services to be terminated and that her actions violated R.C. 5321.15. The court, therefore, found that defendants were entitled to…”
Sacksteder v. Gisslen, 2011 Ohio 6319 (Ohio Ct. App. 2011).
— Ohio Rev. Code § 5321.15(C) — 14 cases
Risch v. Samuel, 2020 Ohio 1094 (Ohio Ct. App. 2020). “15(C) and by failing to take evidence on the hours of her attorney’s service necessitated by Risch’s violation of R.C. 5321.15(A). Samuel contends that the court denied her statutory attorney fees upon its determination that Risch had not violated R.”
Brian Midkiff Monica Midkiff v. Adams Cnty. Reg'l Water Dist., 409 F.3d 758 (6th Cir. 2005). “” Ohio Rev. Code Ann. § 5321.15 (A) provides that a landlord shall not “initiate any act, including termination of utilities or services, .”
Jackson v. Brown, 614 N.E.2d 847 (Ohio Ct. App. 1992). “Brown counterclaimed for compensation for violation of R.C. 5321.15, which states: “(A) No landlord of residential premises shall initiate any act, including termination of utilities or services, exclusion from the premises, or threat of any unlawful act, against a tenant, or a…”
Crenshaw v. Rowland, 965 N.E.2d 341 (Ohio Ct. App. 2011). “28 for past-due rent and for damage to the carpet, the court further found that appellee had breached her duties as a landlord in causing water services to be terminated and that her actions violated R.C. 5321.15. The court, therefore, found that defendants were entitled to…”
Thomas v. Papadelis, 476 N.E.2d 726 (Ohio Ct. App. 1984). “It was an attempt to waive the restrictions imposed on Papadelis, as a landlord, under R.C. 5321.15, for recovery of the premises.”
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