State v. Randolph, 241 N.E.3d 158

The State of Ohio (City of Toledo) charged Antonio Randolph with criminal trespass for entering an apartment unit at Greenbelt Place Apartments, where the property manager had previously barred him from the premises.
Randolph entered the unit at the invitation of his uncle, who was the tenant of the leased property.
There was no evidence that the lease agreement gave the landlord or manager the right to exclude Randolph from the premises.
The municipal trial court convicted Randolph, relying on precedent giving the landlord authority to bar individuals to maintain the quiet enjoyment of tenants.
The Sixth District Court of Appeals reversed, holding that absent lease language to the contrary, the tenant could invite Randolph onto the property.
The Ohio Supreme Court took the case on a certified conflict over whether an owner/landlord can, absent lease agreement language, bar individuals such that tenants lose their right to invite guests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Can a landlord bar a person such that tenants cannot invite them, absent lease language?	Landlord must retain right to bar guests for quiet enjoyment of all.	Tenants cede possessory interests and may invite guests unless stated	Landlords cannot bar guests unless lease reserves this authority.
Does leasing property sacrifice landlord possessory interests, letting tenants invite?	Quiet enjoyment compels landlord authority over access.	Lease cedes possessory rights; only lease can reserve exclusions.	Lease cedes landlord's possessory rights unless stated otherwise.

State v. Herder, 65 Ohio App.2d 70 (10th Dist. 1979) (lease generally cedes possessory rights to tenant, allowing tenant control over who may enter, if not stated otherwise)