Ohio Rev. Code Ann. § 2919.27

A spouse may testify in a prosecution under Section 2919.27 for violating a temporary protection order.

Reynoldsburg v. Eichenberger · filed 1990-05-11

We find that the clear intent of the legislature was to permit the trial court to enter temporary protective orders pursuant to R.C. 2919.26, and to punish their violation pursuant to R.C. 2919.27. To permit a spouse to testify in an action under R.C. 2919.25, but not under its companion statute of R.C. 2919.27, would emasculate the domestic violence legislation and offend the clear legislative purpose in enacting the entire sections.

A court cannot convict someone of violating R.C. 2919.27 when no criminal complaint charges that violation.

Jeffers v. Jeffers, Unpublished Decision (2-13-2001) · filed 2001-02-13

However, no criminal complaint was filed in this case charging appellant with violating R.C. 2919.27 . Therefore, the trial court could not have convicted her of violating R.C. 2919.27 .

Section 2919.27 requires proof that the defendant recklessly violated a protective order issued under Section 2919.26; an order issued without the required timely hearing cannot support a conviction.

State v. Franklin, Unpublished Decision (6-22-2001) · filed 2001-06-22

The elements of the crime in this case are set forth in R.C. 2919.27 , which provides that no person shall recklessly violate the terms of a protective order issued pursuant to R.C. 2919.26 . ... We hold that, absent a timely hearing prior to the issuance of a TPO, the protective order is invalid, as it has not been issued pursuant to R.C. 2919.26 . Therefore, no rational trier of fact could have concluded in this case that Franklin had recklessly violated a valid TPO.

Section 2919.27 requires the State to prove that the defendant recklessly violated the particular terms of a protection order.

Ohio v. Ball, Unpublished Decision (5-4-2001) · filed 2001-05-04

R.C. 2919.27 provides that no person shall recklessly violate the terms of a protection order, which may include proximity restrictions. An essential element which the state has the burden of proving in a violation of R.C. 2919.27 is that the defendant violated the particular terms of the protection order.

Section 2919.27(A)(1) requires a valid protection order; an order issued without the hearing required by section 2919.26 cannot support a charge for violating it.

State v. Finley · filed 2001-10-19(A)(1)

R.C. 2919.27(A)(1) provides that no person shall recklessly violate the terms of a protection order issued pursuant to R.C. 2919.26. ... In this case, Finley never received a hearing as required by R.C. 2919.26(D), and the temporary protection order was therefore ineffective. Consequently, no rational trier of fact could have concluded that he had recklessly violated a protection order issued pursuant to that statute, and the trial court did not err in granting Finley’s motion to dismiss the charge.

Section 2919.27(A)(1) applies to violations of both temporary and permanent protection orders.

State v. Jones, Unpublished Decision (5-28-2002) · filed 2002-05-28(A)(1)

The fact that he had not yet received the permanent order is not relevant as the crime of violating a protection order applies to temporary and permanent orders. R.C. 2919.27 (A)(1), citing R.C. 3113.31 .

Section 2919.27(A) prohibits reckless violation of a protection order issued under Section 2919.26, even if the state later fails to prove the underlying domestic-violence charge.

State v. Cobb · filed 2003-07-18(A)

R.C. 2919.27(A) provides that no person shall recklessly violate the terms of a protection order issued under R.C. 2919.26. ... At the time Cobb violated the order, there had been no determination of his and Likely’s cohabitation status. The fact that the state subsequently failed to prove its case did not negate the fact that Cobb had violated a court order that was valid and effective at the time he had violated it.

A charge under § 2919.27(A)(2) for violating a civil stalking protection order requires proof that the order was issued in compliance with § 2903.214.

State v. Blaine, Unpublished Decision (3-12-2004) · filed 2004-03-12(A)(2)

The state charged Blaine with violating R.C. 2919.27 (A)(2) five times. The pertinent part of R.C. 2919.27 (A)(2) provides, "No person shall recklessly violate the terms of * * * [a] protection order issued pursuant to section * * * 2903.214 of the Revised Code[.]" Thus, R.C. 2903.214 was one of the elements of each of the five offenses that the state had to prove, i.e. that the CSPO was issued in compliance with R.C. 2903.214 .

A conviction under § 2919.27 requires conduct that violates the terms of the protection order.

State v. Ball, Unpublished Decision (3-3-2006) · filed 2006-03-03

Based on the reasoning set forth above, we conclude that appellant Ball's act of driving his car in the vicinity of Estelle's residence when she was not home did not violate the terms of the CPO. As a result, the evidence presented at trial was legally insufficient to sustain his conviction under R.C. § 2919.27 .

An alleged failure to hold the required hearing does not provide a defense to a willful violation of a protection order under § 2919.27.

State v. Sutts, Unpublished Decision (7-6-2004) · filed 2004-07-06(A)(1)

We thus conclude that appellant's allegation that the protection order was invalid does not provide a defense to his willful violation of the order.

Section 2919.27 covers protection orders issued under either R.C. 2919.26 or R.C. 3113.31.

State v. Anderson, Unpublished Decision (10-13-2004) · filed 2004-10-13

James argues in his fourth assignment (which he combines with his third assignment) that he was prejudiced because the complaint in the case numbered 03CRB-36938 stated that he had violated the terms of a protection order issued under R.C. 2919.26 . The order had actually been issued under R.C. 3113.31 . This was legally insignificant. James was convicted under R.C. 2919.27 , which covers both statutes. James was adequately advised of the charges against him, and the variance did not affect the sufficiency of the evidence.

A conviction under § 2919.27 for violating a temporary protection order requires compliance with the service and notice requirements for issuing that order.

State v. Mohabir, Unpublished Decision (1-7-2005) · filed 2005-01-07(A)(1)

Therefore, the statute's due process requirements must be complied with prior to a trial court's finding a violation of a temporary protection order pursuant to R.C. 2919.27 State v. Franklin (June 22, 2001), Hamilton App. No. C-000544. {¶ 35} Upon review, we find the state did not demonstrate the due process requirements of R.C. 2919.26 were complied with in the issuance of the temporary protection order alleged to have been violated. The notation "via jail" is not sufficient to prove service and notice upon the appellant.

Section 2919.27 permits prosecution for violating a protection order issued by a court with jurisdiction even if the order is later found invalid.

Westlake v. Patrick, Unpublished Decision (3-22-2007) · filed 2007-03-22

Therefore, a party may be criminally punished for violating an order even though the order is determined to be invalid after the violation has occurred.

Section 2919.27(A)(1) makes the terms of a protection order, as modified by a divorce decree, the basis for deciding whether contact violates the order.

State v. Price · filed 2008-05-01(A)(1)

Because R.C. 2919.27(A)(1) prohibits the violation of a protection order, the terms of the protection order and divorce decree at issue essentially become part of R.C. 2919.27(A)(1). ... We therefore hold that the divorce decree, which set forth that visitation was to be at the mother’s discretion, created a limited exception to paragraph 6 of the CPO, which forbids contact between a respondent and protected parties.

Section 2919.27(A) makes a reckless violation of a protection order a crime while the order remains in effect, even if the order is later invalidated.

State v. Eschrich, Ot-06-045 (6-20-2008) · filed 2008-06-20(A)

At the time that appellant violated the protection order in the present case, it had not yet been declared invalid by order of this court. Accordingly, his reckless violation of that order was a crime and the trial court did not err in denying his motion to vacate or in proceeding to sentence him.

A consent-agreement protection order cannot support a conviction for conduct before the order is approved by the court and journalized.

State v. Hamlett · filed 2010-12-29(A)(1)

Rather, the CPO was not approved by the court and journalized until August 5 and was thus not effective until that date, which is after the date of the alleged offense.

Section 2919.27(A)(3) requires a violation of an actual term of an out-of-state protection order; conduct prohibited only by federal law does not suffice.

State v. Haney · filed 2011-11-21(A)(3)

We find that while the order provides appellant with notice that he is subject to Section 922(g)(8), neither of the above references to the federal statute expressly incorporates those federal restrictions on firearm possession into the state protection order. Therefore, it appears that appellant possessed firearms while subject to a protection order, in violation of Section 922(g)(8), yet he has not violated any terms of the actual protection order itself.

A person served with an ex parte protection order must obey it until the issuing court cancels or rescinds it, even if the person has not received notice of a later final order.

State v. Hall · filed 2013-12-30(A)(2)

In this case, Hall had no right to disregard the ex parte order unless and until the court that issued the order canceled or rescinded it. ... Accordingly, Hall was properly convicted on all eight (8) counts of Violation of a Protection order under R.C. 2919.27(A)(2).

Section 2919.27 prohibits recklessly violating a protection order; entering a protected child’s school after learning she attends it can satisfy that requirement even if she is absent.

Lyndhurst v. Smith · filed 2015-01-29

R.C. 2919.27, violating protection order, provides in relevant part that “[n]o person shall recklessly violate the terms” of a protection order. ... The protection order states that “respondent shall not enter the * * * school of the protected persons named in this order, including the buildings, grounds, and parking lots of those locations.” It does not list any exceptions or modifications that would allow the respondent to enter for any reason, including if the protected person is not there. ... Thus, the state presented sufficient evidence that Smith recklessly violated the protection order.

Section 2919.27 prohibits reckless violation of a protection order; knowing the order’s terms and entering a prohibited residence can support a conviction.

State v. Cheatham · filed 2016-09-12

On these facts we conclude that there was sufficient evidence to support the trial court's finding that Cheatham acted recklessly when he violated the terms of the CPO in February 2015 by being at Brooks' residence.

Phone calls to a protected person can violate § 2919.27 after the defendant is served with an order barring contact, regardless of who owns the recipient’s phone.

State v. Hilton · filed 2016-12-19(A)

Contrary to appellant’s assertion, it is of no consequence whether he called Ms. Anderla on the “Obama phone,” i.e., his own cell phone, from the telephone at the jail. The protection order specifically stated that he was to have no contact with her whatsoever. ... Accordingly, the state established beyond a reasonable doubt that appellant was served with the protection order before committing the violations, thereby supporting his conviction for violating the order.

A person served with a full protection order cannot defeat a conviction for violating it by claiming lack of notice of the underlying hearing while the order remains in effect.

State v. YBarra · filed 2016-09-01(A)(1)

Appellant was served with the full protection order and therefore was not at liberty to disobey the order on the basis that he had not been served with notice of the underlying hearing. Until the order was successfully attacked on the basis of lack of service of notice of the hearing, the protection order was valid and appellant was required to obey the order.

Section 2919.27 requires proof that the defendant was served with the protection order or received one of the forms of notice specified in subsection (D) before violating it; actual awareness alone is insufficient.

State v. Doss · filed 2019-06-07(D)

Consequently, to show a violation of R.C. 2919.27(A)(1), the state must prove that the defendant recklessly violated the terms of the protection order, and that the defendant was served with the order or otherwise was notified about the order in one of the two ways described in R.C. 2919.27(D).

A conviction for violating a civil protection order requires proof that the order was in effect on the date of the offense.

State v. Brogden · filed 2018-03-02(A)(2)

To prove a violation of a civil protection order, the state is required to prove that the order was in effect on the date of the offense.

A conviction for violating a protection order requires proof of the order; testimony that one existed does not suffice when the order itself was not admitted into evidence.

Cleveland v. Boone · filed 2018-03-08

The city did not present a certified copy of the TPO into evidence, thus failing to support a prima facie element of the offense.

A conviction under § 2919.27 cannot stand when the underlying protection order was expunged and the proceedings deemed not to have occurred before the defendant’s plea.

State v. Jewell · filed 2020-02-10

The ex parte protection order and all records were ordered to be expunged and erased as a record. ... Upon review of the language in the entry, the defendant should not have been convicted of the violation in this matter and the Appellee concedes the error. ... Based upon the State’s concession, we hereby sustain the Assignment of Error and reverse the March 22, 2019 conviction and sentence by the Licking County ... Municipal Court for violation of a protection order. Pursuant to App.R. 12(B), we render judgment that the February 14, 2019 charge against James A. Jewell for violation of a protection order is hereby dismissed.

For a violation of a protection order under the version of § 2919.27(A)(1) applicable to the 2016 offense, the state had to prove beyond a reasonable doubt that the defendant was served with the order before the alleged violation.

Cleveland v. K.C. · filed 2018-09-06(A)(1)

Consequently, in order to obtain a conviction in this case, the state must prove, beyond a reasonable doubt, that K.C. was served with a copy of the protection order he allegedly violated prior to September 15, 2016, the date on which he engaged in conduct that violated the protection order.

Former § 2919.27(A)(2) required proof that the defendant recklessly violated a protection order and had been properly served with it before the violation.

Akron v. Sage · filed 2018-09-12(A)(2)

At the time Sage allegedly violated the ex parte civil protection order in this case, however, former R.C. 2919.27(A)(2) required proof that he recklessly violated the protection order and that the order had been properly served on him prior to the violation.

An unserved protection order can support criminal liability when a law enforcement officer informed the defendant that it had been issued.

State v. Tolle · filed 2020-03-05(D)

In the case sub judice, the evidence affirmatively established that a law enforcement officer informed appellant about the protection order’s existence. As a result, the protection order was effective, and appellant could be held criminally liable for a violation of the order.

Section 2919.27(D) does not require proof that a protection order was served if a law enforcement officer informed the defendant of the order and the defendant recklessly violated it.

State v. Rossing · filed 2020-03-10(D)

In addition, R.C. 2919.27(D) provides that the prosecution need not prove that the protection order was served on the defendant if it proves both that a law enforcement officer informed defendant of the issuance of the protection order and that the defendant recklessly violated the terms of the order. ... The prosecution presented evidence proving both elements.

Section 2919.27(D) does not require proof of service when a law enforcement officer informed the defendant of the protection order and the defendant recklessly violated it; reissuing the same order without substantive changes does not require separate notice.

State v. Lay · filed 2021-03-22(D)

The deputy's notice to appellant satisfied the requirements of R.C. 2919.27(D) because we have determined that there was only one DVCPO issued against appellant.

Section 2919.27(D) allows proof that a defendant knew of a protection order without proof of service, but a violation cannot be established without evidence of that knowledge.

State v. Wilson · filed 2021-04-23(D)

Without evidence of appellant’s knowledge of the CPO, the city failed to establish an essential element to prove a violation of R.C. 2919.27.

Proper service is not an element of a violation of § 2919.27(A).

State v. Moore · filed 2020-07-23(D)

Thus, the state did not have to prove proper service; proper service is not an element of the offense pursuant to R.C. 2919.27(A).

Section 2919.27(D) permits prosecution without perfected service if a law enforcement officer informed the defendant of the protection order and the prosecution proves a reckless violation of its terms.

State v. Kidd · filed 2020-10-22(D)

The lack of perfected service of the protection order will not preclude prosecution for a violation of R.C. 2919.27(A) as long as the prosecution can show, for example, that a law enforcement officer informed the defendant that a protection order had been issued and it proves that the defendant recklessly violated the terms of the order.

A protected party’s statement that a protection order has been dissolved does not give the person subject to the order a good faith basis to violate it.

State v. Conklin · filed 2021-02-16(A)(2)

Third-party misinformation about the status of a court order, in this case, from the protected party of the CSPO, does not create a “good faith belief” that a court order has been dissolved.

Section 2919.27(D) gives the state two alternatives to proving that the defendant was served with the protection order or consent agreement.

State v. Guzman · filed 2021-06-28(D)

R.C. 2919.27(D) provides the State with two alternatives to establishing that the defendant was served with the protection order or consent agreement.

Section 2919.27 requires proof that the defendant was served with the protection order or received the notice specified in subsection (D).

Cleveland v. Bolden · filed 2023-05-04(D)

Thus, to establish a violation of R.C. 2919.27(A)(2), the prosecution had to establish (1) that Bolden recklessly violated the terms of a protection order issued pursuant to R.C. 3113.31, and (2) that Bolden either received service of the protection order or constructive notice of the order as provided in R.C. 2919.27(D).

Section 2919.27(D) does not require proof that the defendant was formally served with the protection order; the State may prove the defendant was shown a copy or informed of its issuance by a judge, magistrate, or law enforcement officer.

State v. Adkins · filed 2023-08-28(D)

Effective September 27, 2017, the State need only prove a defendant was shown a copy of the protection order or was informed of its issuance by a judge, magistrate, or law enforcement officer. R.C. 2919.27(D).

Section 2919.27 prohibits reckless violation of a protection order; a defendant prosecuted under it cannot challenge the order’s validity in the criminal case based on alleged lack of notice of the hearing.

State v. Hall · filed 2022-09-30

Hall’s due-process argument constitutes an improper collateral attack on the protection order. He cannot challenge its validity in a criminal case involving his prosecution for violating it.

Section 2919.27(D) permits conviction without service if the defendant was shown the protection order or informed of it by a judge, magistrate, or law enforcement officer, and recklessly violated its terms.

State v. Fleming · filed 2023-03-17(D)

R.C. 2919.27(D), which was enacted in response to Smith, dispenses with the service requirement if the state proves both that (1) the defendant was shown the protection order or a judge, magistrate, or law enforcement officer informed him of it, and (2) the defendant recklessly violated the terms of the order.

The state must prove the protection order as an element of the offense; an unauthenticated copy is insufficient.

State v. Tarrance · filed 2024-05-22

Because the state did not present a certified copy of the protection order, it failed to prove a prima facie element of the offense.

Proof that the defendant was served with a protection order before the alleged violation satisfies the notice requirement for a prosecution under this section.

State v. Edwards · filed 2024-12-23(D)

Then, through State’s Exhibits 33, 34, 35, and 36, the State of Ohio presented certified copies of the court documents that, when considered together, more than adequately established under the legal standards of review set forth above that Edwards had been served with the protection orders on April 5, 2023 and, therefore, such service had been perfected prior to the offenses at issue in this case, which occurred on April 20, 2023.

An officer’s informing a defendant that a protection order has been issued can satisfy the notice requirement without proof that the order was served.

State v. Brown · filed 2025-02-18(D)

In this case, Sergeant Collier informed Brown of the protection order and advised him, on multiple occasions, that he needed to vacate the residence. This alone is sufficient to satisfy the notice requirement under R.C. 2919.27(D).

The state must prove service of the protection order before the violation unless it proves the defendant was shown the order or was told of its issuance by a judge, magistrate, or law enforcement officer.

State v. Hart · filed 2024-05-28(D)

Accordingly, the state failed to produce sufficient evidence that service of the protection order was completed in accordance with the Civil Rules or that it was relieved of producing such evidence due to proof of one of the circumstances described in R.C. 2919.27(D).

Under the version of subsection (D) applicable in February 2023, the prosecution did not have to prove service of the protection order if it proved a statutory notice exception.

State v. James · filed 2024-08-26(D)

Pursuant to the version of R.C. 2919.27(D) in effect at the time of James entering the home, service of the CPO is not a requirement for conviction as long as one of the statutory exceptions to service is proven.

Section 2919.27(A)(1) permits conviction for violating a protection order while it was in effect, even if the order is later vacated.

State v. Powell · filed 2024-10-11(A)(1)

Applying the same reasoning here, Powell would still be guilty of violating the protection order because she did so before it was vacated.

Section 2919.27(D) does not require the State to prove service of a protection order if the defendant was shown or informed of the order and recklessly violated its terms.

State v. Manes · filed 2025-01-08(D)

In prosecuting a defendant for a violation of the statute, the State need not prove a protection order was served on the defendant so long as the State proves (1) “the defendant was shown the protection order . . . or a judge, magistrate, or law enforcement officer informed the ... defendant that a protection order . . . had been issued,” and (2) “the defendant recklessly violated the terms of the order . . . .” R.C. 2919.27(D).

A later dismissal of a protection order does not undo a violation committed while the order was valid and in effect.

State v. Haas · filed 2025-05-23(A)(2)

K.K. eventually asking the common pleas court to dismiss her CPO petition, and the court “dissolv[ing]” the ex parte CPO does not negate the fact that a valid order, issued by a court with subject-matter jurisdiction, existed on August 26, 2022. Haas was bound to follow that order until the CPO case was dismissed, and the ex parte CPO was dissolved.

Section 2919.27(D) does not require proof that a protection order was served if the defendant was shown the order or informed of it by a judge, magistrate, or law enforcement officer, and recklessly violated its terms.

State v. Edwards · filed 2026-01-16(D)

Since September 27, 2017, R.C. 2919.27(D) has provided that “[i]n a prosecution for a violation of this section, it is not necessary for the prosecution to prove that the protection order or consent agreement was served on the defendant if the prosecution proves that the defendant was shown the protection order or consent agreement or a copy of either or a judge, magistrate, or law enforcement officer informed the defendant that a protection order or consent agreement had been issued, and proves that the defendant recklessly violated the terms of the order or agreement.” ... On this record, the trial court could have reasonably concluded that Edwards was both informed of and served with the final protection order before October 31, 2024.

Certified evidence that a protection order was served and that an authorized official informed the defendant of it can satisfy subsection (D).

State v. Pittman · filed 2026-03-02(D)

Turning to the merits of Ms. Pittman’s argument regarding service of the CSPO, we conclude the evidence was sufficient to prove that Ms. Pittman had been served with the CSPO and that a judge, magistrate, or law enforcement officer informed her of the issuance of the order pursuant to R.C. 2919.27(D).

Section 2919.27 permits a conviction for violating a protection order when evidence shows the defendant initiated a telephone call that the order prohibited.

State v. Justice, Unpublished Decision (9-7-2001) · filed 2001-09-07

A review of the initial exchange between appellant and Ruth provides sufficient evidence from which the jury could conclude appellant initiated the telephone call on June 14, 2000, thereby, violating the August 11, 1999 TPO.

A conviction under section 2919.27(A)(1) may withstand manifest-weight review when the protected person identifies the defendant as a caller and other evidence places him near the calls.

State v. Palicki, Unpublished Decision (5-4-2001) · filed 2001-05-04(A)(1)

Appellant was charged with violating R.C. 2919.27 (A)(1), which provides: ... After examining the entire record below, we cannot say that the jury "lost its way" or created a manifest miscarriage of justice. Appellant was at the bar around the time that the first call was made, and Stefango was certain that appellant, himself, was the second caller.

Section 2919.27(A)(1) prohibits recklessly violating a protection order. A conviction can stand when the trial court credits the protected person’s earlier account over her contrary trial testimony.

City of Akron v. Taylor, Unpublished Decision (12-19-2001) · filed 2001-12-19(A)(1)

Violation of a temporary protection order is governed by R.C. 2919.27 (A)(1) which states that "[n]o person shall recklessly violate the terms of * * * [a] protection order[.]" ... Upon careful review of the testimony and evidence presented at trial, we hold that the trial court did not act contrary to the manifest weight of the evidence in convicting Defendant of violation of a protection order and, therefore, the conviction was sufficient as a matter of law.

Knowingly causing a protected person to fear physical harm can constitute a reckless violation of a protection order that prohibits abuse, harassment, and contact.

State v. Newland, Unpublished Decision (9-27-2002) · filed 2002-09-27(A)

The CPO in this case prohibits the defendant from being within 500 yards of Robin Taylor, and also prohibits abuse, harassment, and contact in person or through another person. If Newland knowingly caused Taylor to fear physical harm, that conduct would also establish a reckless violation of the CPO.

Section 2919.27 treats contact that violates a protection order as reckless when a person knows the order restricts contact but chooses not to read its terms before making contact.

State v. Gordon, Unpublished Decision (12-9-2003) · filed 2003-12-09(A)

However, even if appellant's unsworn assertions that he did not know written communications were prohibited by the CPO were true, his actions and inactions constituted recklessness pursuant to R.C. 2919.27 . Even if his claims that he set the CPO papers aside and did not read them "in detail" were true, he was aware or should have been aware that his voluntary failure to read the order could result in violation of the order. He admittedly knew that the CPO placed restrictions on contacting his wife. Knowing the CPO restricted contact with his wife, his subsequent writings in the face of such knowledge indicate a perverse disregard of a risk that his conduct was likely to cause a CPO violation.

Section 2919.27 prohibits recklessly violating the terms of a qualifying protection order; evidence that a person came within the order’s prohibited distance can support a conviction.

State v. Lemley, Unpublished Decision (10-28-2004) · filed 2004-10-28(A)

R.C. 2919.27 sets forth the essential elements of violating a protection order and provides: "(A) No person shall recklessly violate the terms of any of the following: (1) A protection order issued or consent agreement approved pursuant to section 2919.26 or 3113.31 of the Revised Code; (2) A protection order issued pursuant to section 2903.213 or 2903.214 of the Revised Code; (3) A protection order issued by a court of another state." {¶ 13} Here, the record contains sufficient evidence to support Lemley's convictions for violating the protection orders as the least stringent of the orders precluded him from being within 500 feet of the complainant.

Evidence of a valid protection order and the defendant’s presence within its prohibited distance supported a conviction under § 2919.27.

City of Columbus v. Banks, Unpublished Decision (12-14-2004) · filed 2004-12-14

Here, the testimony of the prosecution's witnesses, if believed, provides sufficient evidence to support the trial court's conclusion defendant was present at Griffin's home at the time of the incident involving Griffin's car and jacket. Specifically, Sydnor testified she heard a noise that awakened her, she went to the window and she there observed defendant smash Griffin's car window and saw Griffin's jacket in his hand. The parties stipulated the validity of the protection order in effect on that day, and Officer Warrick testified that defendant's presence placed defendant closer to Griffin than the protective order allowed. ... Given the testimony before the trial court, we cannot conclude the trial court lost its way in finding the prosecution's evidence more persuasive than defendant's evidence. Accordingly, we overrule defendant's single assignment of error and affirm the judgment of the trial court.

Section 2919.27 requires evidence of a protection order violation; a remark about a gold necklace in a courthouse hallway was insufficient on these facts.

State v. Lemley, Unpublished Decision (1-4-2005) · filed 2005-01-04(A)

Although Sonya Lemley testified that she believed that the appellant's remark concerning a gold necklace constituted harassment, we are not convinced that the substance of the appellant's statement and the setting in which it was made could constitute a R.C. 2919.27 violation. Although we certainly understand and acknowledge the trial court's frustration with the appellant and with the parties' behavior in general, we believe that under these particular facts the evidence falls short of a possible violation.

Section 2919.27 prohibits recklessly violating a protection order; repeated calls to a protected person can provide sufficient evidence of a violation.

State v. Rusu, Unpublished Decision (1-26-2005) · filed 2005-01-26

R.C. 2919.27 provides that no person shall recklessly violate the terms of a protection order. ... However, viewing the evidence in a light most favorable to the prosecution, the State proved that appellant recklessly violated the terms of an existing protection order.

Circumstantial evidence can establish that a defendant recklessly violated a protection order by possessing a prohibited firearm while aware the order remained in effect.

State v. McLean, Unpublished Decision (4-1-2005) · filed 2005-04-01(A)(1)

Construing this evidence in a light most favorable to the prosecution, we hold that the jury could have reasonably found, beyond a reasonable doubt, that McLean recklessly violated the protection order by possessing a handgun in violation of that order.

Section 2919.27 prohibits recklessly violating a protection order; evidence that a defendant went to a protected person's home can support a conviction when the order bars him from going where that person may be found.

State v. Wills, Unpublished Decision (5-9-2006) · filed 2006-05-09

The CPO at issue here provided that appellant shall not be present within 500 feet of the persons listed in the order, and shall refrain from entering any place where they may be found. ... Based on the evidence and testimony of all the witnesses, when viewed in a light most favorable to the prose-cution, we find that a rational trier of fact could have found beyond a reasonable doubt that appellant recklessly violated the CPO.

A conviction for violating a protection order is supported when the order covers the location and credible evidence identifies the defendant there.

State v. Reckers, C-060451 (7-20-2007) · filed 2007-07-20(A)(1)

In the case at bar, it was undisputed that a protection order was in effect and that it covered the area immediately surrounding Picciano's apartment. The only point of contention was whether Reckers was properly identified as the person who had been present in the parking lot. Having held that Goldman's identification testimony was credible with respect to the felonious-assault convictions, we also hold that the conviction under R.C. 2919.27 was proper.

A conviction for violating a protection order can rest on credible testimony that the defendant called the protected person when the order prohibited telephone contact.

State v. Boczek, Unpublished Decision (7-21-2006) · filed 2006-07-21

The protection order clearly prohibited appellant from making any contact, including telephone contact, with Williams. ... Williams' direct testimony that appellant called her cell phone, if believed, is sufficient to establish appellee's case beyond a reasonable doubt.

Section 2919.27 prohibits recklessly violating a protection order; initiating forbidden contact and failing to leave can support a conviction.

State v. Hollingsworth, Ca2006-06-070 (6-4-2007) · filed 2007-06-04(A)(2)

R.C. 2919.27 prohibits the reckless violation of an order of protection. ... In light of the evidence presented, the trial court could reasonably conclude, beyond a reasonable doubt, that appellant had violated the protection order at issue when he initiated contact with D.H. by yelling to her during the parade and by not immediately leaving the parade upon seeing her there.

Evidence that a defendant appeared at the protected person's home despite a no-contact protection order can support a conviction for violating the order.

State v. Donaldson, 24015 (7-23-2008) · filed 2008-07-23(A)(1)

We further do not find that the jury lost its way when it convicted Donaldson of violating a protection order. Roberts testified to the CPO that she obtained ordering Donaldson to have no contact with her. She further testified that she saw him at her back door on August 20, 2007.

Section 2919.27(A)(1) prohibits reckless violation of a protection order; evidence of prohibited contact can support a conviction.

State v. Jackson, 2007ca00342 (10-20-2008) · filed 2008-10-20(A)(1)

Based upon the evidence introduced at trial, the jury did not lose its way in finding Appellant guilty of violating the protection order. The jury was in a better position to observe the witnesses' demeanor and weigh their credibility, and we find the convictions were not against the manifest weight of the evidence.

Section 2919.27(A)(1) prohibits recklessly violating a protection order, and voice identification can establish who made prohibited calls.

State v. Allen · filed 2012-07-20(A)(1)

Defendant was convicted of violation of a protection order in violation of R.C. 2919.27(A)(1), which states that no person shall recklessly violate the terms of any protection order issued against him. ... Although at least eight other inmates had access to the same phone, Farrar testified that Defendant was the only person she knew in the jail at that time. Moreover, Farrar recognized Defendant’s voice in the 15 to 20 messages he left for her during the course of that day and the next. The State introduced a recording of one of those messages into evidence. Defendant’s conviction for violation of a protection order is not against the manifest weight of the evidence.

A conviction for violating a protection order may stand when credible testimony shows that the defendant came within the prohibited distance and contacted the protected person.

State v. Kemper · filed 2012-12-17

Kemper was charged with violating a protection order in violation of R.C. 2919.27. According to the protection order in place, Kemper was ordered not to be within two city blocks of Winters, and could not initiate any contact with her. ... The court found credible Winters' testimony that Kemper was within two city blocks of her and that he made contact with her, thus violating the protection order. After reviewing the record, we cannot say that the trier of fact clearly lost its way and created such a manifest miscarriage of justice that the conviction must be reversed and a new trial ordered.

Section 2919.27(A)(1) prohibits recklessly violating a protection order; evidence that a person knew of the order and entered its prohibited 500-foot zone supported a conviction.

State v. Hunt · filed 2014-09-05(A)(1)

Based on the foregoing evidence, we cannot say the jury lost its way in finding that Hunt recklessly violated the protection order. The record includes evidence demonstrating that Hunt knew the protection order existed and that he decided to come within 500 feet of Sweet anyway.

Evidence of contact prohibited by an effective protection order can support a conviction under § 2919.27(A)(1), even when the order bars contact with the protected person's permission.

State v. Pickens · filed 2014-09-09(A)(1)

The evidence presented at trial established that on January 25, 2012, Ervin and appellant signed a consent agreement and domestic violence civil protection order in accordance with R.C. 3113.31, whereby appellant was required to vacate Ervin's residence, ... to refrain from initiating contact or having contact with Ervin, and to not be within 500 feet of Ervin even with Ervin's permission. ... When viewed in a light most favorable to the prosecution, as is required for a review of the sufficiency of the evidence supporting a criminal conviction, Ervin's testimony and the remaining evidence presented by the prosecution was sufficient to support appellant's convictions for aggravated burglary and violation of a protection order.

A conviction for violating a protection order can be supported by evidence of the approximate date charged despite mistaken testimony naming a different year.

State v. Brown · filed 2014-12-12(A)(1)

We find that there was sufficient evidence that the violation occurred on or about “January 11, 2013” as charged in the indictment. While appellant agreed with the prosecutor that appellant had been incarcerated with Stuart in January “2012,” the jury could reasonably concluded that the prosecutor and appellant both erred by stating “2012” since appellant also testified that he was incarcerated as of January 3, 2013.

A jury may find a reckless violation of a civil stalking protection order when a person approaches someone protected by the order and attempts to speak with her despite the order’s restrictions.

State v. Sims · filed 2016-10-14(A)(2)

From this evidence, we find the jury could have determined that appellant recklessly disobeyed the civil stalking protection order by attempting to speak with Steck.

Subsection (A)(2) prohibits recklessly violating a protection order; evidence that a person entered an area barred by an order he had received can support a conviction.

State v. Seibert · filed 2017-12-18(A)(2)

Both the victim and her father indicated that Seibert lived directly below the victim such that, when he walked into his apartment, he was well within 500 feet of her. Accordingly, the record reflects that the State satisfied its burden of production.

Section 2919.27(A)(1) prohibits recklessly violating a protection order; following a protected person and communicating beyond the order’s permitted parenting discussions supported a conviction.

State v. Putman-Albright · filed 2016-01-29(A)(1)

Having reviewed the entire record, weighed the evidence and all reasonable inferences, we cannot conclude that the trial court lost its way and created a manifest miscarriage of justice in convicting Tina of twice violating R.C. 2919.27(A)(1) such that Tina is entitled to a new trial. ... We conclude that Tina, with heedless indifference to the consequences, followed Donald in her car on his way home and communicated with him in a manner prohibited by the protection order.

Section 2919.27 prohibits recklessly violating the terms of a protection order; glaring can support a conviction when the order forbids it.

State v. Bradbury · filed 2016-07-25

Bradbury was convicted of violating R.C. 2919.27, which prohibits a person from recklessly violating the terms of a protection order. ... After viewing this testimony in a light most favorable to the prosecution, we find that the state was able to prove the charge beyond a reasonable doubt.

To prove a violation of a protection order, the prosecution must prove that the defendant violated a term of the order in effect at the time.

Strongsville v. N.D. · filed 2016-10-27(A)(1)

In order for the city to prove that N.D. violated a temporary protection order pursuant to R.C. 2919.27, the city had to prove that N.D. violated a term of the protection order that was in effect at the time of the violation.

A conviction for violating a protection order can rest on circumstantial evidence that the defendant sent messages prohibited by the order.

State v. Plummer · filed 2016-10-31(A)(1)

As noted above, Plummer was convicted of violating a DVCPO by contacting his former live-in girlfriend, A.B., through a series of text messages in violation of R.C. 2919.27(A)(1). ... However, the record ... firmly establishes that the text messages sent to A.B. originated from Plummer's phone and included a "pet name" that Plummer often called A.B. throughout their two-year relationship, a name A.B. testified only she and Plummer knew. ... Therefore, because the state presented evidence from which the jury, as the trier of fact, could find all the elements of the offense proven beyond a reasonable doubt, Plummer's conviction was supported by sufficient evidence and was otherwise not against the manifest weight of the evidence.

Section 2919.27 permits a conviction for violating a domestic violence civil protection order when circumstantial evidence shows threats of abuse against the protected person.

State v. Parke · filed 2019-09-05

In this case, we find the threatening language in the Facebook post that included details Parke would know, the blue truck parked outside of Jane Doe’s residence, and the related Facebook exchanges between Parke and Jane Doe lead to the inference that Parke violated the terms of the domestic violence civil protection order by committing threats of abuse against the petitioner, Jane Doe.

A conviction under section 2919.27(A)(1) can be supported by credible witness testimony that the defendant was within the distance prohibited by a protection order, without a map or actual measurement.

State v. Sullivan · filed 2020-04-13(A)(1)

Appellant was convicted of Violating a Protection Order, in violation of R.C. 2919.27(A)(1), which provides: “No person shall recklessly violate the terms of any of the following: (1) A protection order issued * * * pursuant to section 2919.26 or 3113.31 of the Revised Code.” ... After viewing the evidence in a light most favorable to the prosecution, we conclude that any rational juror could have found the essential elements of Violating a Protection Order proven beyond a reasonable doubt.

Section 2919.27(A)(1) permits a conviction when a person aware of a protection order recklessly enters its restricted distance from a place the protected person is likely to be; attempted contact is unnecessary.

State v. Rhoades · filed 2020-04-28(A)(1)

Viewing the evidence in the light most favorable to the state, a rational trier of fact could have found beyond a reasonable doubt that Rhodes was guilty of violating R.C. 2919.27(A)(1) by being at the stop sign at the end of Joos Avenue on the block where Jaide's residence was located, because he was aware of the Protection Order and disregarded a substantial and unjustifiable risk that being in that location would place him within 500 feet of Jaide or a place she was likely to be while the Protection Order was in effect and prohibited such conduct.

A protected person’s testimony can establish that a defendant recklessly came within the distance prohibited by a protection order.

State v. Almeyda · filed 2021-02-19(A)(1)

Groh’s testimony regarding Almeyda’s conduct was clear and was sufficient to establish that, with heedless indifference to the consequences, he came within 500 feet of her—a violation of the protection order. We conclude that Almeyda’s conviction was not against the manifest weight of the evidence, which means that the evidence was also sufficient to support the conviction.

Section 2919.27 requires proof that the defendant recklessly violated a protection order, and the protected person's testimony can supply sufficient evidence of the offense.

State v. Burns · filed 2021-04-29

... there was insufficient evidence to prove that he "recklessly" violated a protection order as required to prove that charge under R.C. 2919.27. {¶ 10} We disagree. ... Here, J.B.'s testimony alone provides firm evidence for each and every element of the five crimes.

Placing a card on a protected person's car and emailing her employer can violate § 2919.27(A)(2) when the protection order forbids that contact.

State v. Szykulski · filed 2021-08-10(A)(2)

Thus, the state presented sufficient evidence that Szykulski violated a protection order by placing the card on E.E.B.'s windshield and by emailing her employer.

Section 2919.27(A)(2) prohibits recklessly violating a protection order issued under R.C. 2903.214; evidence of service and conduct within the order’s prohibited distance can support a conviction.

State v. Sizemore · filed 2021-11-24(A)(2)

R.C. 2919.27(A)(2) states, in pertinent part, that “no person shall recklessly violate * * * a protection order issued pursuant to * * * [R.C.] 2903.214.” When the evidence is viewed in the light most favorable to the prosecution, Sizemore was served with the protection order, the protection order was issued under R.C. 2903.214, the protection order prohibited Sizemore from being within 500 feet of Prater, and, when he was arrested, Sizemore was within 500 feet of Prater. Given this evidence, it would be frivolous to assert that Sizemore’s conviction was not based upon sufficient evidence.

Section 2919.27(A)(1) prohibits recklessly violating a protection order, including by coming within a distance the order forbids.

State v. Daylong · filed 2021-11-30(A)(1)

From this evidence, a rational jury could conclude Daylong recklessly violated the terms of the protection order by coming within 500 feet of her.

Section 2919.27 prohibits recklessly violating a protection order; credible testimony that a defendant came within the distance barred by the order can support a conviction.

State v. Hensley · filed 2021-10-18

Hensley was convicted of violating a protection order in violation of R.C. 2919.27, which provides that "[n]o person shall recklessly violate the terms of * * * [a] protection order issued pursuant to section * * * 2903.214 of the Revised Code." ... Earl's testimony, if believed, establishes that Hensley violated the CPO by coming within 50 feet of her when he walked through her neighbor's yard on the way to Elsie's.

Following and photographing people protected by an active order can support a conviction for violating the order when its terms prohibit that conduct.

State v. Bennington · filed 2023-03-03

Bennington appears to concede that the actions she took on March 16, 2022, violated R.C. 2919.27. She admits, and the evidence showed, that Bennington followed V.C.M. and her children to the Speedway station and then took pictures of them. This violated the protection order against her.

A conviction under Section 2919.27(A)(1) can be supported by evidence that the defendant received a no-contact protection order and repeatedly called the protected person.

State v. Patterson · filed 2023-10-02(A)(1)

The TPO, which was issued on November 18, 2022, ordered Appellant to have no contact with M.F. Martin stated Appellant received, and signed he had received, a copy of the TPO. Deputy Waltz testified he conducted an ICS Enforcer search for the time period between November 18, 2022, and February 7, 2023, which revealed Appellant placed a total of 1,237 calls or attempted calls to M.F.’s phone number. ... In addition, Lt. Allensworth identified the individuals on the jail calls as Appellant and M.F. ... Based upon the foregoing, we find Appellant’s conviction was based upon sufficient evidence and was not against the manifest weight of the evidence.

Section 2919.27(A)(1) requires proof that a person recklessly violated a protection order; testimony that the person called the protected party, without more evidence about the calls, was insufficient.

State v. Brady · filed 2024-01-26(A)(1)

The record contains no evidence regarding the amount of times Brady called Hart, whether Brady was, in fact, the person placing the telephone calls, whether Hart answered the calls, or what Brady’s purpose was in placing the calls. As the state concedes, the record contains no evidence that Brady recklessly violated the terms of the protection order.

Section 2919.27(A)(1) prohibits recklessly violating a protection order; evidence of prohibited contact after the order was served can support a conviction.

State v. Farris · filed 2024-03-08(A)(1)

We find that a rational trier of fact could find evidence demonstrating that appellant recklessly violated the terms of the September 21, 2020 civil protection order, disregarding a substantial and unjustifiable risk that the conduct was likely to cause a certain result, constituting the offense of violation of a protection order.

Section 2919.27(A)(1) prohibits recklessly violating a protection order; evidence that a defendant came within the order’s 500-foot limit can support a conviction.

State v. Huffman · filed 2024-05-06(A)(1)

Accordingly, the evidence, when viewed in the light most favorable to the State, would convince the average mind beyond a reasonable doubt that Mr. Huffman came within 500 feet of C.P. and was guilty of violating a protection order.

Call records and voice identification can support a finding that a defendant made a call prohibited by a protection order under section 2919.27.

State v. Jennings · filed 2024-08-12(A)

Appellant was convicted of violating a protection order in violation of R.C. 2919.27: ... From the evidence presented, we find a rational trier of fact could find Appellant placed the telephone call to the victim. We also find the jury did not lose its way in concluding Appellant was the person who placed the call.

A conviction for violating a protection order withstands manifest-weight review when evidence shows that the defendant repeatedly tried to contact the protected person after an order issued under R.C. 2903.213.

State v. Heckler · filed 2025-05-27(A)(2)

With regard to his conviction for Violating a Protection Order, there was clear testimony and documentation that K.S. received a criminal protection order against Heckler pursuant to R.C. 2903.213. The protection order was obtained August 21, 2023, and it was entered into evidence. K.S. testified that Heckler attempted to contact her numerous times after the order was obtained, including ... repeatedly from another inmate’s tablet. This testimony was corroborated by an investigator who looked into the matter and saw from the recorded calls Heckler was trying to contact K.S. Based on the evidence presented, we do not find that Heckler’s conviction for Violating a Protection Order was against the manifest weight of the evidence.

Section 2919.27(A)(2) covers a reckless violation of a protection order’s ban on harassment through egregious conduct and derogatory comments toward the protected person.

State v. Craddock · filed 2025-06-09(A)(2)

Therefore, while we render no opinion as to whether Craddock violated the protection order issued against her by merely coming onto K.J.'s property with Deputy Wessline, Craddock clearly violated the protection order by engaging in unnecessarily egregious behavior upon entering onto K.J.'s property and making derogatory comments towards K.J. after being told by Deputy Wessline not to "engage or anything" with her.

Section 2919.27(A) requires the State to prove that the defendant recklessly violated the terms of a protection order.

State v. Glaeser · filed 2025-07-07(A)

Further, to obtain ... a conviction for violating a protection order in violation of R.C. 2919.27(A), the State must prove that the defendant “recklessly violate[d] the terms of . . . [a] protection order . . . .”

Circumstantial evidence linking a person to prohibited text messages can support a conviction for violating a protection order.

State v. Owens · filed 2025-09-18(A)(1)

When Owens answered a text from detectives, he identified himself as "Cory." Additionally, when Detective Burgess met with Owens at his home and called the suspect number twice while at the home, Owen's phone chimed both times. ... While circumstantial, the testimony and record contain ample evidence of Owens' responsibility for the crime.

Section 2919.27 does not require proof of the specific date of a violation when the evidence shows the prohibited contact occurred after the defendant received the protection order.

State v. Gardner · filed 2026-05-29(A)(2)

Though Hammond’s testimony was not specific to the August 15 date without exhibit No. 6, R.C. 2919.27 does not require a specific date; all the State had to prove was that Gardner sent the messages after August 12.

Section 2919.27(A)(1) prohibits reckless violation of a protection order, and the person protected by the order may be charged with aiding the restrained person’s violation.

State v. Lucas · filed 2002-04-25(A)(1)

Although we do not disagree with the Eighth District’s recitation of the General Assembly’s purpose enacting temporary protection laws, we disagree with the court’s conclusion that the victim of domestic violence cannot be charged as an aider and abetter in the violation of a protection order by an offender because the victim is a member of a protected class. ... R.C. 2919.27(A)(1) states that no person shall recklessly violate the term's of a protection order issued pursuant to R.C. 2919.26 or 3113.31.

A person protected by a protection order cannot be criminally charged with violating it by inviting the respondent into her home.

State v. Youngpeter, Unpublished Decision (1-31-2005) · filed 2005-01-31

However, in this case, Youngpeter's assertion that she could not be criminally charged with a violation of a protection order is supported by law. After reviewing the record, it appears that there was a specific misunderstanding and mistake of law by the court and the prosecution as to whether Youngpeter could be charged with violating the protection order that she obtained against Roger Lewis.

A protected person’s permission for the respondent’s presence does not excuse a violation of a protection order.

State v. Krause · filed 2021-10-12(A)(1)

While the evidence suggests Ms. Rosipko may have permitted Mr. Krause’s presence at times, that fact would not affect Mr. Krause’s culpability.

A protected person’s permission does not excuse contact that a protection order expressly prohibits even with that permission.

State v. Bennett · filed 2022-12-30(A)(1)

Accordingly, L.C.’s alleged acquiescence in having contact with Mr. Bennett did not preclude a violation of the protection order.

Section 2919.27(A)(1) prohibits reckless violation of a protection order, and an invitation from the protected person does not excuse contact forbidden by the order.

State v. Simpson · filed 2024-06-21(A)(1)

For a violation of R.C. 2919.27(A)(1), the State had to demonstrate that Simpson recklessly violated the terms of a protection order or consent agreement. ... Ohio courts have also weighed in on the issue, concluding that an invitation does not negate the power of a protection order. ... There was a protection order in place protecting M.F. from Simpson, and Simpson violated it when he went to M.F.’s condo and made contact with her.

Section 2919.27(A)(1) prohibits violating a protection order issued under section 2919.26 or 3113.31; repeated attempts to contact the protected person supported convictions under the section.

State v. Heald · filed 2025-08-25(A)(1)

R.C. 2919.27(A)(1) provides that no person shall violate the terms of a protection order issued pursuant to R.C. 2919.26 or 3113.31. ... Trial testimony established that Appellant made repeated attempts to contact Scheibelhoffer from the Lake County Jail, including calling her phone from his inmate telephone PIN on September 23, 2024, September 28, 2024, and September 30, 2024. ... Appellant’s convictions for Violating a Protection Order are not against the manifest weight of the evidence.

A protected person’s invitation does not authorize contact barred by a protection order; knowingly living with that person despite the order satisfies the recklessness requirement.

State v. Dalton · filed 2025-05-20(A)(1)

Thus, the evidence shows he not only recklessly violated a protection order but intentionally did so, living with A.W. knowing it was prohibited despite her invitation.

Section 2919.27 requires proof of recklessness to establish a protection-order violation.

Westlake v. Patrick, Unpublished Decision (8-25-2005) · filed 2005-08-25

Fifth, the behavior to which it applies may also constitute an offense under R.C. 2919.27 , but in such instance, the additional element of recklessness must be established.

Section 2919.27(A)(1) requires proof that a person recklessly violated a protection order; violation is not a strict liability offense.

City of Cleveland v. Rogers, Unpublished Decision (7-11-2002) · filed 2002-07-11(A)(1)

Thus, the record shows that the court's conviction of Rogers is based on its mistaken belief that violation of a protection order is a strict liability offense, when in fact a conviction under R.C. 2919.27 requires the state to prove that Rogers acted recklessly when he made the voice mail contact regarding visitations of Christina.

Section 2919.27(A)(1) requires a reckless violation of a protection order; a chance meeting between the people subject to the order is not a crime.

State v. Lucas · filed 2003-09-24(A)(1)

The inclusion of the mental state of “recklessly” in R.C. 2919.27(A)(1) ensures that if there is a chance meeting between the subjects of a protection order, the result is not a crime.

Section 2919.27(A)(1) prohibits reckless violations of domestic violence protection orders, and an addressed envelope can constitute prohibited contact even if it contains only blank paper.

State v. Mustaine, Unpublished Decision (7-14-2000) · filed 2000-07-14(A)(1)

R.C. 2919.27 (A)(1) provides that no one shall recklessly violate the terms of a domestic violence protection order. ... The question raised by this appeal is whether a rational trier of fact could have looked at this evidence and concluded that Mustaine had acted with perverse disregard of a known risk that his conduct would result in a violation of the protection order through contact with his ex-wife. We answer this question in the affirmative. ... Moreover, a rationale trier of fact could certainly have concluded that Robyn Mustaine's receipt of the envelope from Mustaine constituted contact with her, notwithstanding the fact that the papers inside the envelope were blank.

Section 2919.27(A)(1) prohibits recklessly violating a protection order issued under § 3113.31, including by following and harassing someone the order protects.

State v. Havard, Unpublished Decision (12-10-2001) · filed 2001-12-10(A)(1)

Appellant was found guilty of violating R.C. 2919.27 , which states in pertinent part: "(A) No person shall recklessly violate the terms of any of the following: (1) A protection order issued * * * pursuant to section 2919.26 or 3113.31 of the Revised Code." ... Appellant's actions violated the terms of the civil protection order which prohibited, among other things, "following, * * * bothering, harassing, [and] annoying."

Section 2919.27(A)(1) requires proof that the defendant recklessly violated the terms of a protection order.

State v. Dean, Unpublished Decision (6-3-2002) · filed 2002-06-03(A)(1)

The CPO and its terms were facts required to be proven by Appellee as part of the essential elements of the charge of violation of a protection order, which elements are: 1) recklessly; 2) violating the terms; 3) of a protection order. R.C. 2919.27 (A)(1).

Section 2919.27(A)(1) does not make a person who is barred from initiating contact liable merely for failing to prevent someone else from contacting the protected person on their own initiative.

State v. Kersey, Unpublished Decision (1-21-2004) · filed 2004-01-21(A)(1)

While it also prevents him from using others to contact her, it does not require him to prevent those around him from contacting her on their own initiative. Thus, Kersey's mere failure to prevent others from contacting Lyle does not result in his violating the protection order. It is only when those "others" are acting on Kersey's behalf or at his request, that Kersey violates the protection order. ... After viewing the evidence in a light most favorable to the prosecution, we conclude no rational trier of fact could have found the essential elements of R.C. 2919.27 (A)(1) proven beyond a reasonable doubt.

Section 2919.27(A)(1) prohibits recklessly violating the terms of a protection order, including a ban on personal contact.

State v. Pruiett, Unpublished Decision (6-23-2004) · filed 2004-06-23(A)(1)

R.C. 2919.27 (A)(1) prohibits one from recklessly violating the terms of a protection order. ... Evidence in the record supports that Defendant intended to have personal contact with Gills on at least two occasions after the TPO was entered: once by meeting her at the Laundromat and once by confronting Gills at Stephenson's house.

Mailing a letter to a protected residence can violate a protection order’s prohibition on contact, even when the letter is addressed to a pet.

State v. Frazier · filed 2004-08-27(A)(1)

R.C. 2919.27(A)(1) provides, “No person shall recklessly violate the terms of * * * [a] protection order issued or consent agreement approved pursuant to section 2919.26 or 3113.31 of the Revised Code.” ... Under the terms of the criminal protection order, Thomas Frazier was not permitted to have any contact with the residence occupied by Rita Frazier and the children. ... The state adduced evidence that Thomas Frazier had violated the order by sending a letter to the residence. And while the letter was addressed to the family cat, the court was justified in rejecting that transparent ruse and finding that Thomas Frazier was attempting to contact the persons listed in the protection order.

A person who sees the protected person, circles back, and comes within a protection order's 100-yard limit can violate the section regardless of an accompanying gesture.

State v. Whelan, Unpublished Decision (9-29-2004) · filed 2004-09-29(A)(1)

Thus, the trial court articulated sufficient reasons to conclude that Mr. Whelan violated the Order, irrespective of the nature of the vulgar gesture. He was obligated to stay beyond 100 yards from Janet, yet his conduct demonstrates that he did not do so.

Calling a protected person's workplace to try to reach them, while knowing a protection order forbids telephone contact, supports a conviction for recklessly violating the order.

State v. Mohamed, Unpublished Decision (9-20-2005) · filed 2005-09-20(A)(1)

Through her testimony the state (1) identified defendant as the perpetrator, (2) established that defendant not only recklessly placed the telephone calls in violation of the protection order, but apparently purposely did so, and (3) demonstrated that, through the telephone calls, defendant attempted to contact Farah, the protected person under the civil protection order admitted into evidence, even though defendant knew he was to have no contact by telephone or otherwise with Farah.

Text messages can violate a no-contact protection order under § 2919.27(A)(2), and circumstantial evidence may prove who sent them.

State v. McCaleb, Unpublished Decision (9-8-2006) · filed 2006-09-08(A)(2)

R.C. 2919.27 (A)(2) states: "No person shall recklessly violate the terms of . . . [a] protection order issued pursuant to section . . . 3113.31 of the Revised Code." ... The protective order limited Defendant's conduct, and by its terms encompassed Defendant's use of his cell phone to contact Hangen. ... This evidence, if believed, and when construed in a light most favorable to the State, permits a reasonable inference by the trier of facts that is sufficient to prove, beyond a reasonable doubt, that Defendant sent the text messages to Hangen on January 10, 2005, violating the protection order requiring him to have no contact with Hangen.

When a protection order does not specify when weapons must be surrendered, a reasonable time to comply is presumed.

State v. King, Unpublished Decision (2-23-2005) · filed 2005-02-23(A)(1)

Because the order failed to specify when the weapon was to be turned over, a reasonable amount of time to do so will be presumed. Appellant was released from the Tuscarawas County Jail on March 5, 2003, and as of March 7, 2003 had not yet complied with the terms of the protection order, despite ample opportunity to comply. We find, appellant's conviction is supported by competent, credible evidence and the jury did not lose its way in finding appellant guilty.

Section 2919.27(A)(1) prohibits recklessly violating a domestic violence protection order; evidence that a person knew of the order and made prohibited contact can support a conviction.

State v. Davidson, Unpublished Decision (12-15-2004) · filed 2004-12-15(A)(1)

R.C. 2919.27 (A)(1) provides that no person shall recklessly violate the terms of a protection order issued under R.C. 3113.31 , which governs domestic violence protection orders. ... We conclude the state offered sufficient evidence from which a reasonable trier of fact could find that Mr. Davidson knew about the protection order. Moreover, after viewing the evidence in a light most favorable to the prosecution, we conclude that a reasonable trier of fact could find that Mr. Davidson recklessly violated the protection order.

A person who is served with a protection order may act recklessly by failing to read it or listen to an explanation of its terms before violating it.

State v. Cardinal, Unpublished Decision (9-29-2006) · filed 2006-09-29(A)(1)

After reviewing the record and considering the arguments of the parties, it is clear to this court that the jury did not lose its way in finding that appellant was reckless when he violated the terms of the CPO. He was given every opportunity to be aware of all details of the provisions of the CPO, and yet exhibited a carelessness and recklessness in failing to read both CPOs and failing to listen to Deputy Eddy that far exceeds mere negligence.

Section 2919.27 requires proof of a protection order, so evidence that the order existed is relevant to the charge.

State v. Howard, Unpublished Decision (9-29-2005) · filed 2005-09-29

It is apparent that the State never went beyond presenting evidence of the existence of the temporary protection order, which, of course, was the single element of the crime of violation of a temporary protection order.

Section 2919.27(A)(1) requires recklessness; contact initiated by the protected person does not excuse a violation of an order that prohibits contact.

State v. Simms, Unpublished Decision (6-13-2006) · filed 2006-06-13(A)(1)

In this case, it is clear that appellant acted knowingly, a higher culpable mental state than the element of recklessness required for a violation of R.C. 2919.27 . His claim that he was merely returning her call does not ring true when considered in light of his recorded conversations. Moreover, the protection order does not contain any exception to the order for contact initiated by the victim. The protection order prohibits contact, period. Such circumstances may well mitigate the offense; they do not negate the offense.

Entering a protected person's workplace while aware of the protection order and knowing it is the person's workplace supports a finding of reckless violation under § 2919.27.

Beavercreek v. Levalley, 06-Ca-51 (4-27-2007) · filed 2007-04-27

LeValley was convicted under R.C. § 2919.27 , which makes it a crime to recklessly violate a protection order. ... At trial, the State presented evidence establishing that LeValley entered the Kroger store with awareness of the protection order and with awareness that the Kroger store was Nichole's place of employment. Therefore, the trial court's finding that LeValley recklessly violated the order is not against the manifest weight of the evidence.

Section 2919.27 prohibits recklessly violating the terms of a protection order issued under section 2903.213 or 2903.214.

State v. Wallace, 21040 (7-6-2007) · filed 2007-07-06

The police reports also supported Wallace's convictions on the violation of a protection order and the telephone harassment charge. ... Ms. Wallace produced a copy of the protection order which prohibited such telephone harassment by the defendant. (See offense report dated October 11, 2004.) R.C. 2919.27 provides that no one shall recklessly violate the terms of a protection order issued pursuant to R.C. 2903.213 or R.C. 2903.214 . ... We agree with the trial court that these reports support the defendant's guilt on his no-contest pleas.

Section 2919.27 prohibits recklessly violating the terms of a protection order.

State v. Hamilton, Unpublished Decision (9-28-2007) · filed 2007-09-28

A person violates R.C. 2919.27 when that person recklessly violates the terms of a protection order.

Section 2919.27(A)(1) prohibits recklessly violating a protection order, and circumstantial evidence can establish the defendant's awareness of the protected person's location.

State v. Collier, 2006 Ca 102 (11-30-2007) · filed 2007-11-30(A)(1)

The court convicted Collier of violating a protection order in violation of R.C. § 2919.27 (A)(1), which provides that no person shall recklessly violate the terms of a protection order issued under R.C. § 3113.31 , which governs domestic violence protection orders. ... From these facts, it is perfectly reasonable for a trier of fact to infer that Collier was aware that Glenn lived in the apartment complex. Thus, sufficient evidence was adduced at trial by which a trier of fact could find that Collier recklessly violated the terms of if the protection order against him.

Section 2919.27(A)(2) prohibits recklessly violating a protection order issued under section 2903.213 or 2903.214, including an order barring possession of a deadly weapon.

State v. Neville, 07 Co 11 (3-10-2008) · filed 2008-03-10(A)(2)

R.C. 2919.27 (A)(2) prohibits any person from "recklessly violating] the terms of * * * [a] protection order issued pursuant to section 2903.213 or 2903.214 of the Revised Code." ... After Neville's arrest, officers checked his criminal history and discovered that Neville was subject to a protection order issued under R.C. 2903.213 from Clermont County, Ohio, which stated that Neville "shall not possess, use, carry, or obtain any deadly weapon." ... These facts clearly proved all the elements of the offenses that Neville was charged with.

Phone calls and a letter to a protected person can support a conviction under subsection (A)(1) when the protection order bars that contact.

State v. Bulin, 2008-Ca-00045 (11-3-2008) · filed 2008-11-03(A)(1)

{¶ 23} Appellant was charged with three counts of violating a protection order in violation of R.C 2919.27 (A) (1) which states: ... {¶ 26} The State alleged that appellant violated a protection order on three occasions — by calling Lisa on the phone on September 2 and September 10, 2007, and a third time by sending her a letter in October 2007. ... {¶ 33} We conclude the trier of fact, in resolving the conflicts in the evidence, did not create a manifest miscarriage of justice so as to require a new trial. Viewing this evidence in a light most favorable to the prosecution, we further conclude that a rational trier of fact could have found beyond a reasonable doubt that appellant was guilty of three counts of violating a protection order.

Section 2919.27 supports a conviction when evidence shows that a defendant contacted a protected person after a temporary protection order barred that contact.

State v. Cross · filed 2011-06-30(A)

After viewing the evidence in the light most favorable to the State, we conclude that the trier of fact could reasonably find that the State met its burden of production and presented sufficient evidence that Cross violated a temporary protection order which prohibited contact with Williams.

Phone messages to a person protected by a no-contact order can support a conviction for violating the order when testimony identifies the dates of the messages.

State v. Pierce · filed 2011-10-11(A)

This is sufficient to show that appellant attempted to contact her sister in violation of the protective order.

A conviction under Section 2919.27 can withstand a manifest-weight challenge when the jury credits testimony that the defendant threatened the protected person despite conflicting testimony.

State v. Worthy, 23791 (3-31-2008) · filed 2008-03-31(A)

Ms. Worthy argues that the jury lost its way in finding that she acted "recklessly" on March 22, 2007, when the two women ended up at KFC at the same time. ... Based on the foregoing, this Court concludes that Ms. Worthy's conviction was not against the manifest weight of the evidence.

A conviction for violating a protection order can be sustained when the evidence shows the defendant drove on a road the order prohibited and the jury could reject his claim that he went there for permitted visitation.

State v. Zaciek, Ot-08-036 (1-30-2009) · filed 2009-01-30(A)

The record shows that the civil protection order prohibited appellant from driving on North Alpine Road, where Mathews' cottage was located. ... While appellant claims that his purpose in driving to the cottage was to pick up his daughter for visitation the jury, which had the opportunity to observe both appellant and Mathews at trial, could reasonably have believed otherwise.

Section 2919.27(A)(2) requires a reckless violation of a protection order, so an accidental violation is not punishable under it.

Luttrell v. Younce · filed 2011-09-02(A)(2)

The “recklessly” language in R.C. 2919.27(A)(2) provides an additional safeguard that Younce will not be punished for an accidental violation of paragraph 5 of the civil protection order.

When a protection order prohibits contact through another person, having someone else write and send a letter to the protected person violates § 2919.27(A)(1).

State v. Gauer, 2007-Ca-00241 (11-3-2008) · filed 2008-11-03(A)(1)

Thus, even if appellant had someone else write the letter, he still violated the protective order.

Repeated gestures toward a protected person and waiting near his home can provide sufficient evidence of the recklessness required to violate a protection order.

State v. Headlee, 08ca6 (2-19-2009) · filed 2009-02-19(A)(2)

R.C. 2919.27 (A)(2) states that "no person" shall "recklessly violate" the terms of a protection order." ... This evidence is more than sufficient to prove the reckless culpable mental state.

A person can recklessly violate a protection order by disregarding a known risk that entering a nearby property puts him within the order's exclusion distance.

State v. Stoner, 2008 Ca 83 (5-1-2009) · filed 2009-05-01(A)(1)

Although Stoner denied that he intended to violate the CPO or that he was aware that his presence at the Heriers' home violated the order, the trial court could reasonably infer from his conduct that Stoner, with heedless indifference to the consequences, perversely disregarded a known risk that his presence at the Heriers would place him within 500 feet of Tristin or a place where she was likely to be.

Section 2919.27 covers a prohibited message sent to a protected person through a third party.

State v. Kemery · filed 2011-11-18

There was no reason to subject the Downings to the ramblings of the email except to convey the message to Ms. Rowan in contravention of the mandates of the civil protection order.

Section 2919.27 prohibits recklessly violating a protection order; evidence of knowledge of the order and attempts to contact the protected person can support a conviction.

State v. Leason · filed 2011-12-21

Such evidence creates a reasonable inference of Leason’s knowledge of the existence of the protection order and an attempt to hide his attempt to contact the victim by using another inmate’s PIN. Accordingly, the State presented sufficient evidence of the crime of violation of a protection order.

Circumstantial evidence can support a conviction under Section 2919.27 when it permits a jury to find that the defendant drove within an area barred by a protection order.

State v. Smith · filed 2012-02-01(A)

A jury could reasonably infer that, based upon the witnesses’ identification of Smith as the driver of the truck shortly before and after the conduct at issue, that Smith drove the truck twice past Whitsett’s aunt’s home. ... Accordingly, insofar as Smith challenges the sufficiency of the evidence in regard to his conviction for violating a protection order, his first assignment of error is overruled.

Section 2919.27(A)(1) prohibits recklessly violating a protection order, including through prohibited contact with the protected person.

State v. Reber · filed 2012-06-12(A)(1)

We find sufficient evidence exists appellant was reckless with regard to violation of the protection order on February 24, 2011. By Reber’s own testimony, she was present outside the muffler shop and drove by yelling out the window. ... Having weighed the record, we find there was sufficient evidence, if believed by the finder of fact, to establish appellant violated the protection order on each of the indicated dates.

Section 2919.27(A)(1) prohibits recklessly violating a protection order; evidence that the defendant knew of the order and had contact with the protected person was sufficient to support a conviction.

State v. Sales-Hilton · filed 2012-12-05(A)(1)

A person is guilty of violating a protection order if he or she “recklessly violate[s] the terms of * * * a protection order issued * * * pursuant to [a charge of domestic violence] * * *.” R.C. 2919.27(A)(1). ... Viewing the evidence in a light most favorable to the prosecution, a reasonable juror could have concluded that Hilton was aware of the protection order and was with Murray that August morning. Thus, the State presented sufficient evidence to support the conclusion that Hilton had violated the protection order, and the court did not err in denying her motion for acquittal.