In re D.L., 2015 Ohio 4747

D.L. was adjudicated delinquent for theft as a fourth-degree felony under former R.C. 2913.02(B)(2).
Schafer, an ATM technician, withdrew money and left a burlap bag with $2,000 in his car; the bag later disappeared.
Surveillance shows D.L. and his brother A.K. near the deli; A.K. is seen taking money from the bag and placing it near a dumpster.
The bag was recovered with $1,600; fingerprint evidence connected D.L. to the scene.
Police later recovered $1,015 from a hotel room with D.L., A.K., and their mother, Russell; Russell implicated Turner as the instigator.
The state failed to authenticate a withdrawal slip to prove the exact value of stolen property between $7,500 and $150,000.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether value evidence supports fourth-degree felony theft	D.L. argues value was not proven between $7,500 and $150,000.	State contends some evidence establishes value sufficient for the offense.	Value not proven; remanded for fifth-degree finding.

State v. Smith, 121 Ohio St.3d 409 (2009) (value as an element of enhancement, not element)
In re Washington, 75 Ohio St.3d 390 (1996) (sufficiency review standard)
In re Booker, 133 Ohio App.3d 387 (1999) (sufficiency framework for delinquency cases)
State v. Sexton, 2011-Ohio-5246 (1st Dist. 2011) (victim testimony can establish value)
State v. Jones, 2014-Ohio-3740 (10th Dist. 2014) (value evidence considerations in theft)
In re Wells, 2008-Ohio-6688 (1st Dist. 2008) (lack of firsthand knowledge undermines value proof)
Condit v. Condit, 2010-Ohio-5202 (1st Dist. 2010) (evidentiary foundations and admissibility)
State v. Pesec, 2007-Ohio-3846 (11th Dist. Portage No. 2006-P-0084, 2007) (value proof for theft; specific-dollar ranges)