State v. Thompkins

2026-Ohio-812 · Ohio Court of Appeals, First Appellate District, Hamilton County · March 11, 2026 · No. C-250277

Summary

The Ohio First District Court of Appeals affirmed a restitution award of $6,341.43 imposed on Carlos Thompkins following his misdemeanor falsification conviction. The court held that the trial court did not abuse its discretion by deducting certain restaurant charges while including other alleged fraudulent transactions in the restitution amount. The court concluded that the award was supported by competent, credible evidence and reasonably related to the victim's economic loss.

Holdings

  1. The trial court did not abuse its discretion by ordering Thompkins to pay $6,341.43 in restitution.
  2. A restitution award must bear a reasonable relationship to the victim's actual loss and must be supported by competent, credible evidence allowing the amount to be determined to a reasonable degree of certainty.

Questions Presented

  1. Whether the trial court abused its discretion by ordering $6,341.43 in restitution.
  2. Whether the restitution award was supported by competent, credible evidence and bore a reasonable relationship to the Foundation's economic loss.

Disposition

affirmed

Cases Cited (11)

  • State v. Moore, 2023-Ohio-3318, ¶ 10 (1st Dist.)(followed)
  • State v. Miles, 2021-Ohio-4581, ¶ 5 (1st Dist.)(followed)
  • In re A.B., 2021-Ohio-4273, ¶ 8 (1st Dist.)(followed)
  • In re M.N., 2017-Ohio-7302, ¶ 8 (1st Dist.)(followed)
  • State v. Caldwell, 2023-Ohio-355, ¶ 14 (4th Dist.)(followed)
  • State v. Dunn, 2026-Ohio-241, ¶ 15 (1st Dist.)(followed)
  • State v. Haskett, 2024-Ohio-5933, ¶ 14 (1st Dist.)(followed)
  • State v. Gutherie, 2020-Ohio-501, ¶ 23 (1st Dist.)(followed)
  • State v. Lalain, 2013-Ohio-3093, paragraph one of the syllabus(followed)
  • State v. McKinney, 2025-Ohio-4826, ¶ 9 (1st Dist.)(followed)

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Cited In (0)

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