State v. Roberts, 2014 Ohio 115

Latonya Roberts was convicted of aggravated vehicular assault after the victim suffered serious physical injuries.
At sentencing, the trial court imposed community control and ordered Roberts to pay restitution for the victim’s medical bills.
No documentation or testimony establishing the amount of the victim’s medical expenses was presented at the sentencing hearing.
Roberts did not object to the restitution order at sentencing, so plain-error review applies on appeal.
The State concedes that no competent, credible evidence of the specific restitution amount was in the record.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court may order restitution in an indefinite amount to be determined later	State: restitution may be ordered as part of sentence; remand unnecessary if victim later proves damages	Roberts: ordering an indefinite restitution amount without evidence violates due process and R.C. 2929.18	Court: Reversed — indefinite restitution without evidentiary support is plain error; remand for hearing
Whether the court erred by not holding an adequate restitution hearing or otherwise establishing amount	State: hearing not needed if record contains sufficient evidence of loss	Roberts: record lacked competent, credible evidence of economic loss to a reasonable degree of certainty	Court: Reversed — no evidence of amount in record; an evidentiary hearing is required to determine restitution amount

Marbury v. State, 104 Ohio App.3d 179 (appellate standard for restitution requiring reasonable relationship to loss)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (abuse-of-discretion standard defined)
Adams v. State, 62 Ohio St.2d 151 (abuse-of-discretion discussion)
Long v. State, 53 Ohio St.2d 91 (plain-error burden to show different outcome)
Gears v. State, 135 Ohio App.3d 297 (restitution must be supported by competent, credible evidence)
Brumback v. State, 109 Ohio App.3d 65 (hearing not required when record itself substantiates loss)