In re J.A., 2012 Ohio 2184

J.A. was adjudicated a delinquent child for vandalism (fourth degree felony), two counts of criminal damaging (second-degree misdemeanors), and hit/skip; driving without a license, seat belt, and fail-to-control charges were dismissed.
As part of dispositional relief, the juvenile court ordered restitution but did not fix the amount or payment method, instead scheduling a restitution hearing.
The court also suspended J.A.’s ability to obtain a driver’s license until his eighteenth birthday.
J.A. appealed claiming error in restricting his future licensure rights, raising a single assignment of error.
The appellate court dismissed the appeal for lack of finality because restitution was unresolved and left for future proceedings.
The dismissal was based on the restitution order not being a final, appealable order due to unresolved amount/mayment method and the scheduled restitution hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court’s restitution order is final and appealable	J.A. argues the license-restriction ruling is final and reviewable	The state contends restitution remains unresolved, so the order is not final	Lack of finality; restitution unresolved means no appeal

In re Holmes, 70 Ohio App.2d 75 (Ohio App.2d 1980) (restitution amount not fixed renders judgment non-final)
State v. Korosi, 2011-Ohio-2524 (2011) (restitution unresolved affects finality)
State v. Thompson, 2011-Ohio-1564 (2011) (entry sets restitution for hearing; not final)
State v. Phillips, 2008-Ohio-5101 (2008) (restitution to be determined; not final and appealable)
State v. Kuhn, 2006-Ohio-1145 (2006) (intermediate decisions leave issues unresolved)
In re Zakov, 107 Ohio App.3d 716 (1995) (restoration of restitution issue foregrounds interlocutory status)
Eddie v. Saunders, 2008-Ohio-4755 (2008) (inaction on restitution can deny finality)