State v. Jones, 2016 Ohio 7293

On December 3, 2014, an occupied apartment in Toledo was burglarized; televisions and two laptops were stolen. A neighbor and a postal worker observed three young Black men carrying electronics shortly after the burglary and saw a white Oldsmobile Aurora nearby.
Within minutes, three young men attempted to sell laptops at Guy Buys Books; they returned later and completed the sale using appellant Tyrell Jones’s identification. Security video and a pawn/purchase record were admitted.
The victim identified the recovered laptops as his; televisions were not recovered. Detective Cowell obtained admissions from Jones that he pawned the laptops and owned a white Oldsmobile, though Jones initially denied pawning.
Jones was convicted after a bench trial of burglary (R.C. 2911.12(A)(3)) and receiving stolen property (R.C. 2913.51(A)). Trial court sentenced 24 months for burglary and 10 months for receiving stolen property, to run concurrently with each other but consecutively to a separate two‑year term, and ordered restitution “not to exceed $2,130.00.”
On appeal Jones raised three assignments: (1) restitution invalid because not a sum certain and unsupported, (2) insufficient evidence to sustain burglary conviction (identification), and (3) burglary conviction against the manifest weight of the evidence.

Issue	State's Argument	Jones's Argument	Held
Sufficiency of evidence to prove Jones was one of the burglars	Evidence (witness sightings, timing, video, purchase records, victim ID, Jones’ admission he pawned laptops and owned a white Oldsmobile) supports identification beyond a reasonable doubt	State failed to prove identification of Jones as one of the burglars	Affirmed — evidence was sufficient to convict for burglary
Manifest weight of the evidence	Trial court reasonably credited the witness descriptions, video, pawn records, victim ID, and Jones’s admissions; not an exceptional case to overturn	Conviction is against manifest weight; identifications uncertain and inconsistent	Affirmed — verdict not against manifest weight
Restitution amount requirement	Court can base restitution on estimates/receipts and must ensure it does not exceed victim’s economic loss	Restitution order “not to exceed $2,130.00” is indefinite and contrary to R.C. 2929.18(A)(1) which requires the court to determine an amount	Reversed in part — restitution must be a sum certain; remanded for the trial court to determine a specific amount (hearing if disputed) within 30 days

State v. Jenks, 61 Ohio St.3d 259 (establishes the Jackson/Jenks sufficiency standard for criminal convictions)
State v. Thompkins, 78 Ohio St.3d 380 (distinguishes sufficiency from manifest-weight review)
State v. Lang, 129 Ohio St.3d 512 (2011) (clarifies manifest-weight review and the narrow circumstances for granting a new trial)
State v. Brennan, 88 N.E.2d 281 (discusses that subsequent possession of stolen property is evidence from which a trier of fact may infer guilt)