State v. Daniels, 2014 Ohio 5160

Daniels was charged with criminal damaging, criminal trespass, and theft; he pleaded guilty to misdemeanor theft and other charges were dismissed.
On March 4, 2014 the trial court journalized a sentencing entry: 180 days jail (150 suspended), 30 days credit, one year probation, and scheduled a restitution hearing for April 1, 2014.
A restitution hearing was held April 1, 2014; the victim testified to $1,950 in economic loss.
The trial court journalized an April 1 entry ordering Daniels to pay $1,950 restitution as a condition of probation.
Daniels appealed the April 1 restitution entry, arguing the trial court lacked authority to order $1,950 restitution.
The appellate court sua sponte examined jurisdiction and determined the April 1 entry was not a final appealable order under Crim.R. 32(C) and controlling Ohio Supreme Court precedent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the April 1, 2014 restitution entry is a final appealable order (so the appellate court has jurisdiction)	The State implicitly treated the restitution order as part of sentencing and enforceable (i.e., that the order could be reviewed)	Daniels argued the trial court lacked authority to order $1,950 restitution and appealed the April 1 order	The April 1 restitution entry is not a final appealable order because it does not contain the fact of conviction and the full sentence as required by Crim.R. 32(C); appeal dismissed for lack of jurisdiction

Whitaker-Merrell Co. v. Geupel Constr. Co., 280 N.E.2d 922 (Ohio 1971) (appellate courts must dismiss appeals where no final appealable order exists)
State v. Lester, 958 N.E.2d 142 (Ohio 2011) (Crim.R. 32(C) requires fact of conviction, sentence, judge’s signature, and clerk’s journal stamp for a final judgment of conviction)
State v. Baker, 893 N.E.2d 163 (Ohio 2008) (a single document must constitute the final appealable judgment of conviction; multiple documents cannot be combined to satisfy Crim.R. 32(C))