In re M.N., 2017 Ohio 7302

Minor M.N. was adjudicated delinquent after admitting unauthorized use of a vehicle; he appealed the juvenile court’s restitution order.
Victim Meece reported her car stolen; police recovered it and a car key was recovered from M.N. after his arrest.
Meece testified she kept spare keys (including house keys) and registration (with home address) in the car; she spent $175 to rekey the car and $230.53 to rekey her home.
Meece said the police recommended rekeying because the offender may have made a copy of the master key and her registration contained her address.
Juvenile court ordered $1,369.16 restitution; M.N. challenged the $405.53 rekeying award as not an economic loss nor proximately caused by his offense.
The majority affirmed, holding rekeying restored the victim’s pre-offense security and was a proximately caused economic loss; a separate opinion concurred in part and would have excluded the home rekeying amount for lack of evidence of access.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether rekeying costs are recoverable as "economic loss" under R.C. 2152.20	State: Victim’s out-of-pocket rekeying costs are an economic loss caused by the delinquent act	M.N.: Rekeying was a noneconomic, precautionary security upgrade not proximately caused by his unauthorized use	Court: Rekeying restored pre-offense security and was an economic loss proximately caused by the act (majority)
Whether the record supports awarding home rekeying costs	State: Police recommendation and victim’s circumstances justify home rekeying restitution	M.N.: No evidence he accessed spare keys or registration; speculative security concern	Court: Majority: award valid; Dissent: would exclude home rekeying for lack of evidence

In re M.A., 61 N.E.3d 630 (Ohio Ct. App.) (restitution review standard in juvenile matters)
State v. Portentoso, 878 N.E.2d 76 (Ohio Ct. App.) (restitution must reasonably relate to actual loss)