State v. Jackson, 2022 Ohio 807

Stefhan Jackson pleaded guilty in six felony cases (aggravated robbery, felonious assault, aggravated burglary, burglary, and multiple firearm specifications) as part of a plea bargain.
Trial court imposed an aggregate prison term of 20 to 23 years on September 21, 2020.
One case (Cuyahoga C.P. No. CR-20-650761) was sentenced under the Reagan Tokes Law: a three-year firearm specification to be served prior to a 6–9 year indefinite term for burglary, ordered consecutively.
The court ordered restitution to victims in five matters (amounts: $167; $500; $270; $300; $2,000); the prosecutor presented victim requests and a sentencing memorandum; a presentence investigation report existed.
Defense counsel did not object to the restitution amounts at sentencing and told the court he had “no information to the contrary.”
Jackson appealed, raising (1) Reagan Tokes’ constitutionality (separation of powers and due process) and (2) insufficiency of proof for restitution.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Jackson)	Held
Constitutionality of Reagan Tokes indefinite sentence	Reagan Tokes valid; sentence properly imposed in CR-20-650761	Law violates separation of powers and due process	Affirmed; this court’s en banc decision in Delvallie rejects Jackson’s challenges; sentence upheld
Sufficiency of proof for restitution	Restitution properly based on victim requests, PSR, and prosecutor’s memorandum; no objection at sentencing	Amounts were estimates and unsupported; should be vacated	Affirmed; no plain error or abuse of discretion—victim requests/PSR and lack of objection support restitution

State v. Marbury, 104 Ohio App.3d 179 (8th Dist. 1995) (abuse-of-discretion standard for restitution review)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (definition of "abuse of discretion")