State v. Beckwith, 2022 Ohio 2362

Beckwith was charged in two separate 2018 cases with menacing by stalking; he pled guilty to one count in each case pursuant to a plea agreement.
While released pretrial, the court required GPS inclusion-exclusion monitoring and no-contact conditions; Beckwith removed the ankle monitor, fled to Georgia, and was later extradited.
At sentencing (Oct. 20, 2021) the court imposed consecutive 18-month terms (total 36 months) and ordered $725 to the sheriff for the damaged GPS device and $1,890 to the prosecutor for extradition; the court had earlier declared Beckwith indigent.
The State acknowledged the entries mistakenly labeled these amounts as "restitution" and argued the monitor cost was recoverable under R.C. 2929.18(A)(5)(a) and the extradition cost under R.C. 2949.14.
The appellate court held both payments could not properly be ordered as restitution (and extradition costs could not be assessed against a court-declared indigent); it vacated the $725 and $1,890 orders and otherwise affirmed the conviction and sentence.

Issue	State's Argument	Beckwith's Argument	Held
Whether cost to repair/replace damaged GPS ankle monitor could be ordered as restitution or reimbursement	Monitor cost recoverable as government "reimbursement" under R.C. 2929.18(A)(5)(a)	Device damage not a direct/proximate result of stalking; monitor was a pretrial bond condition (not a sentencing "sanction"); government not a restitution "victim" here	Vacated $725. GPS monitoring was a pretrial condition, not a sanction for which R.C. 2929.18(A)(5)(a) permits reimbursement; not restitution under R.C. 2929.18(A)(1)
Whether extradition costs may be imposed as restitution/costs	Extradition costs routinely imposed on felony defendants under R.C. 2947.23 and recoverable via R.C. 2949.14	Court had earlier found Beckwith indigent; R.C. 2949.14 permits recovery only from nonindigent convicted felons	Vacated $1,890. Extradition expenses cannot be assessed against a defendant the court has declared indigent
Ineffective-assistance challenge to restitution orders	State would oppose	Beckwith argued counsel was ineffective in failing to object	Moot (court vacated restitution orders on other grounds)

State v. Lalain, 136 Ohio St.3d 248, 994 N.E.2d 423 (2013) (restitution must be based on victim's economic loss directly and proximately caused by the offense)
State v. Maurer, 146 Ohio St.3d 118, 63 N.E.3d 534 (2016) (trial courts may order extradition costs but journal entries must reflect the sentence actually pronounced)
State v. Gapen, 104 Ohio St.3d 358, 819 N.E.2d 1047 (2004) (distinguishing pretrial electronic monitoring from postconviction confinement/house arrest)
Antoon v. Cleveland Clinic Found., 148 Ohio St.3d 483, 71 N.E.3d 974 (2016) (statutory language must be applied according to its plain meaning)
Centerville v. Knab, 162 Ohio St.3d 623, 166 N.E.3d 1167 (2020) (government can be a victim for restitution in certain property-damage contexts)
State v. Taylor, 163 Ohio St.3d 508, 171 N.E.3d 290 (2020) (definitions and limits on recovery of costs associated with electronic monitoring/house arrest)