Columbus v. Wood, 2016 Ohio 3081

On May 26, 2015 Wood was cited for leaving the scene of an accident (hit‑skip), failing to drive within his lane, and violating his temporary permit; he later pled guilty to hit‑skip in exchange for dismissal of the other charges.
At plea Wood was pro se and admitted lack of license, lack of insurance, and that he left the scene; the court reserved restitution for a later hearing.
At the November 17, 2015 sentencing hearing the city presented an unstamped/unnumbered damage estimate (transcript reflects $5,993.09); the written entry listed $5,999.09 restitution.
Wood, then represented, sought to withdraw his plea claiming he did not understand restitution exposure; the court denied the continuance and imposed community control, fines, license suspension, and restitution.
The trial court did not make an explicit finding that the economic loss was the direct and proximate result of Wood’s operation of the vehicle before, during, or after the hit‑skip offense, and it ordered more than $5,000 in restitution.
The court of appeals reversed: remanded for a new restitution hearing to decide proximate causation and limited any restitution under the ordinance to $5,000.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether restitution may be ordered without an explicit finding that the victim’s loss was a direct and proximate result of the hit‑skip offense	City relied on transcript estimate and argued restitution was appropriate tied to the accident	Wood argued the vehicle damage was not the proximate result of leaving the scene and the court failed to make required findings	Reversed: court must determine whether the economic loss was the direct and proximate result of Wood’s operation of the vehicle before, during, or after the offense before ordering restitution
Whether the court could order restitution in excess of $5,000 under Columbus Traffic Code 2135.12(b)(1)	City sought the full claimed amount (~$5,999)	Wood argued the ordinance caps restitution at $5,000	Reversed: restitution under the ordinance is limited to $5,000 and the trial court exceeded its authority

Columbus v. Cardwell, 176 Ohio App.3d 673 (2008) (holding property damage from a collision is not necessarily a direct and proximate result of a hit‑skip violation)
Ackison v. Anchor Packing Co., 120 Ohio St.3d 228 (2008) (distinguishing cause in fact from proximate cause)
Anderson v. St. Francis‑St. George Hosp., 77 Ohio St.3d 82 (1996) (discussing causation standards)
Mussivand v. David, 45 Ohio St.3d 314 (1989) (proximate cause requires foreseeability; natural and probable consequence test)
Strother v. Hutchinson, 67 Ohio St.2d 282 (1981) (analysis of proximate causation principles)