State v. Walls, 2014 Ohio 3502

Defendant Cameron Walls pleaded guilty to receiving a stolen diamond ring and reserved restitution amount for sentencing.
Victim (the purchaser) testified he paid $3,200 for the custom white-gold ring with diamonds but had no receipt, appraisal, or insurance documentation; jeweler was out of business.
Defense challenged the sufficiency of that testimony to establish the ring’s value for restitution purposes.
Trial court found the purchaser credible and ordered restitution; appellate review applied the competent, credible evidence standard for factual findings.
Appellate court affirmed, concluding the purchaser’s testimony—as owner-opinion evidence—was adequate to establish economic loss.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether victim’s oral testimony without receipts/appraisal suffices to prove value for restitution	Victim’s sworn recollection of purchase price is competent, credible evidence; owners are presumed to know value	Oral declaration is insufficient; prosecution should have offered documentary proof because defendant cannot effectively rebut price	Testimony was sufficient; owner-opinion rule and credibility determination supported restitution amount

State v. Warner, 55 Ohio St.3d 31 (1990) (appellate review of restitution amount is for competent, credible evidence)
Tolkes & Son, Inc. v. Midwestern Indem. Co., 65 Ohio St.3d 621 (1992) (owners may testify to value of their property by virtue of ownership)
State v. Didion, 173 Ohio App.3d 130 (2007) (application of competent, credible evidence standard in restitution reviews)
State v. Marbury, 104 Ohio App.3d 179 (1995) (restitution must bear a reasonable relationship to actual losses; speculative awards are reversible)