State v. Lalain, 136 Ohio St. 3d 248

Lalain pled guilty to fifth-degree-felony theft involving property valued $500–$5,000; restitution was ordered at sentencing in the amount of $63,121.
Aero-Instruments sought restitution for costs to investigate the theft and value the stolen property, including $55,456 for employee time and $7,665 for Meaden & Moore valuation work.
The sentencing court incorporated a company letter detailing the alleged losses but Lalain’s counsel disputed the connection of those costs to the theft.
The Eighth District Court of Appeals affirmed restitution without an evidentiary hearing, and noted a conflict with State v. Ratliff over whether such costs exceed the value corresponding to the theft degree.
The Supreme Court held that restitution cannot exceed the victim’s economic loss directly and proximately caused by the offense and that a hearing is required if the amount is disputed; it dismissed the certified conflict as improvidently certified.
Ultimately, the case was remanded for further proceedings consistent with the opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is restitution capped by the economic loss tied to the offense?	Lalain says restitution may not exceed the loss tied to the fifth-degree theft.	State argues the court may order restitution based on victim’s estimated costs and other information.	Yes; restitution cannot exceed economic loss directly caused by the offense.
Must a hearing be held if the offender disputes the restitution amount?	Lalain contends a hearing was required since the amount was disputed.	State contends a hearing is unnecessary absent a dispute.	A hearing is required when the offender disputes the restitution amount.

State v. Ratliff, 194 Ohio App.3d 202 (2011-Ohio-2313 (2d Dist.)) (limits restitution to value corresponding to the theft degree (conflicts with broader recoveries))
State v. Danison, 105 Ohio St.3d 127 (2005-Ohio-781) (restitution as part of sentence; framework for penalties)