State v. Lee, 2019 Ohio 4725

Defendant Crishandra Lee pled guilty to two counts of forgery after presenting forged/stolen checks and cashing them at Lebanon Citizens National Bank (LCNB) and Fifth Third Bank.
Each bank paid Lee in cash; subsequently each bank reimbursed its accountholder for the improperly paid check (LCNB $1,345; Fifth Third $1,159).
At sentencing the state sought restitution payable to the banks for the amounts they had reimbursed the accountholders.
The trial court held the banks were third parties, not “victims” under the restitution statute, and denied restitution to the banks.
The state appealed, arguing Marsy’s Law’s expanded constitutional definition of “victim” (a person "directly and proximately harmed by the commission of the offense") includes banks that suffered the economic loss.
The appellate court reversed and remanded, concluding LCNB and Fifth Third were victims entitled to restitution under R.C. 2929.18 as informed by Marsy’s Law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether banks that reimbursed accountholders after a forged check were "victims" entitled to restitution	Banks are directly and proximately harmed by the forgery and thus are victims under Marsy’s Law and R.C. 2929.18	Banks are third parties who reimbursed their customers and therefore are not "victims" for restitution purposes	Reversed: banks are victims under Marsy’s Law and may be awarded restitution for their economic loss

State v. Allen, 153 Ohio St.3d 1452 (Ohio 2018) (case addressing whether a bank that reimburses a customer is a "victim" for restitution)
State v. Ritchie, 174 Ohio App.3d 582 (5th Dist. 2007) (held R.C. 2930.01(H)(1)’s definition of "victim" is specific to Chapter 2930)