State v. Jones, 2020 Ohio 81

Tranell Jones pleaded guilty to one count of attempted misuse of a credit card (first-degree misdemeanor) after using her employer’s credit card without permission to rent a storage container from 1-800-Pack-Rat, LLC.
The employer (an elderly woman Jones cared for) discovered the unauthorized charge and the credit card company reversed the charge, causing an economic loss to Pack Rat.
At sentencing the trial court imposed three years of community control and ordered Jones to pay $90.94 restitution to Pack Rat; the court stayed the restitution at Jones’s request.
Jones appealed, arguing Pack Rat was not a “victim” entitled to restitution under R.C. 2929.18 because it was not the employer and (implicitly) was not the person directly charged in the criminal case.
The trial court had relied on Marsy’s Law (Ohio Const. Art. I, § 10a) to find Pack Rat was a victim entitled to restitution; the appellate court reviewed the restitution order for abuse of discretion (legal question of victim definition reviewed de novo).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Pack Rat is a "victim" entitled to restitution under R.C. 2929.18	State: Pack Rat suffered economic loss from Jones’s deception and is a victim under Marsy’s Law	Jones: Pack Rat was not the victim of her crime and thus not entitled to restitution	Pack Rat is a victim under Marsy’s Law and restitution was proper
Whether trial court abused its discretion in ordering restitution	State: Ordering $90.94 restitution for Pack Rat is within the court’s statutory authority	Jones: Ordering restitution to Pack Rat was an abuse because Pack Rat was not a named victim under prior statutory definitions	No abuse of discretion; restitution order affirmed

No officially reported authorities with Bluebook reporter citations are cited in the opinion. (The opinion discusses State v. Thornton, State v. Adams, and State v. Allen, among others, but these are cited without official reporter citations in the opinion.)