State v. Crum, 2013 Ohio 903

Crum was indicted by a Delaware County Grand Jury on two theft counts and one misuse of credit cards count arising from use of a company credit card at Thorson’s Greenhouse.
He pled guilty to one theft count; the other counts were dismissed; the trial court sentenced him to three years of community control and ordered restitution of $1,597.42.
Appellant challenged the restitution amount on appeal, arguing it wasn’t supported by evidence and whether third‑party reimbursement occurred was unclear.
The trial court’s restitution order was reviewed for support by competent, credible evidence and under an abuse of discretion standard.
The court held that the evidence supported the amount of restitution but remanded to determine if the victim was reimbursed by a third party.
The appellate court affirmed in part, reversed in part, and remanded for a determination on third‑party reimbursement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Restitution amount supported by evidence?	Crum contends the amount is not supported.	Crum disputes the sufficiency of the record to prove economic loss.	Restitution amount supported by credible evidence.
Whether third‑party reimbursement affects restitution amount?	If third parties reimbursed, victim lacks economic loss, affecting restitution.	Record does not show third‑party reimbursement clearly.	Remand to determine if third‑party reimbursement occurred.

State v. Aliane, 2004-Ohio-3730 (10th Dist. 2004) (restitution must be supported by competent, credible evidence)
State v. Williams, 34 Ohio App.3d 33 (2nd Dist. 1986) (abuse of discretion standard for restitution orders)
State v. Jamison, 49 Ohio St.3d 182 (1990) (credibility is for the trier of fact)
State v. Kiser, 2011-Ohio-5551 (2nd Dist. 2011) (third‑party reimbursement impacts economic loss)
State v. Kelly, 2011-Ohio-4902 (4th Dist. 2011) (third‑party reimbursement considerations in restitution)