State v. McDonald, 2011 Ohio 1964

McDonald was charged in April 2009 with burglary, passing bad checks, aggravated menacing, and criminal damaging in Cuyahoga County.
In June 2010 she pled guilty to passing bad checks and aggravated menacing; all other charges were dismissed.
She was sentenced to one year in prison and ordered to pay $6,900 in restitution.
On appeal, McDonald argues the guilty plea was not properly informed under Crim.R. 11(C)(2).
She also challenges the restitution order as excessive and not tied to actual losses.
The court affirms in part, modifies the restitution amount, and remands for entry of judgment reflecting the reduced restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the plea colloquy complied with Crim.R. 11(C)(2).	McDonald asserts failure to inform rights/waiver specifics	McDonald contends lack of strict compliance invalidates plea	Plea colloquy complied; no reversible error
Whether restitution was properly limited to the offense-related losses.	State seeks $6,900 including nonrelated damages	Nonpayment of rent was not caused by the offense; restitution should be limited	Abused discretion; amount reduced to $1,800; remanded for judgment entry reflecting reduction

State v. Veney, 120 Ohio St.3d 176 (2008) (strict Crim.R. 11(C)(2) rights-waiver disclosure required)
State v. Williams, 34 Ohio App.3d 33 (1986) (restitution must bear reasonable relationship to loss)
State v. Marbury, 104 Ohio App.3d 179 (1995) (restitution evidence must show actual losses)
State v. Hafer, 144 Ohio App.3d 345 (2001) (restitution limited to actual economic loss)
State v. Hooks, 135 Ohio App.3d 746 (2000) (restitution must relate to offense-convicted)
State v. Warner, 55 Ohio St.3d 31 (1990) (economic loss standard for restitution)