State v. Olson, 2013 Ohio 4403

Olson pled guilty to aggravated theft and no contest to grand theft and theft, with restitution as part of the plea but without fixed amounts.
The trial court held a restitution hearing and, on July 7, 2011, ordered restitution to three victims: FJM $115,672.11, MCG $49,178.78, and MEPA $2,384.34.
Olson appealed contending the restitution amounts were incorrect or unsupported by evidence.
The appellate court partially sustained and partially affirmed the restitution orders, reversing some amounts and remanding others for further proceedings.
A central legal issue was whether certain costs (accounting and legal fees) and misapplied funds were properly includable as economic loss under R.C. 2929.18(A)(1) and Lalain.
The court ultimately reduced the FJM restitution to $58,411.41 (removing $57,261 in accounting/legal fees) and vacated the MCG award, remanding for a proper calculation; MEPA restitution was affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the FJM restitution amount included impermissible costs	Olson	Olson	Partially sustained; remove accounting/legal fees, leaving $58,411.41.
Whether the MCG restitution amount was supported by evidence	State	Olson	Sustained; vacate and remand for proper determination.
Whether the MEPA restitution amount was properly awarded	State	Olson	Overruled; MEPA restitution affirmed.

State v. Lalain, Ohio St.3d 2013-Ohio-3093 (2013) (economic-loss limit; excludes documenting costs from restitution)
State v. Johnson, 164 Ohio App.3d 792 (2005) (burden on victim to prove restitution amount; broad discretion to trial court)
State v. Sommer, 154 Ohio App.3d 421 (2003) (evidence standard for restitution awards; needs competent, credible evidence)
State v. Alcala, Ohio 2012-Ohio-4318 (2012) (restitution limits; costs of documenting loss may be excluded)
State v. Gears, 135 Ohio App.3d 297 (1999) (restitution must be supported by evidence to a reasonable degree)