State v. Allen, 101 N.E.3d 734

Allen pleaded guilty to seven counts of forgery after cashing multiple counterfeit checks at several banks.
The checks were drawn on accounts identified as belonging to Park Club Apartments, Tuttle's Grove Apartments, and Progressive Flooring Services.
Allen admitted he knew the checks were counterfeit and that another person gave him the checks and asked him to cash them.
At sentencing the state sought restitution payable directly to Middlefield Banking Company, First Merchants Bank, and Chase Bank for the amounts they paid on the forged checks.
Allen objected, arguing the banks had reimbursed their customers and thus were third parties, not the victims entitled to restitution under R.C. 2929.18.
The trial court ordered three years community control and restitution to the three banks; the appellate court reversed and vacated the restitution order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a bank that paid out on forged checks is a "victim" entitled to restitution under R.C. 2929.18	Banks that paid the checks suffered the economic loss and are therefore victims entitled to restitution	Banks reimbursed the true account holders and are third parties; the account holders, not the banks, suffered the direct economic loss	Reversed: banks that reimbursed customers are third parties and not victims for restitution purposes

State v. Lalain, 136 Ohio St.3d 248 (Ohio 2013) (discusses trial court discretion to order restitution for victim's economic loss)