State v. Haskett

Citations

• 2024 Ohio 5933

Syllabus

CRIMINAL — RESTITUTION — ECONOMIC LOSS — INSURANCE — CROSS-EXAMINATION: The trial court did not err in awarding the victim the full cost to repair damage to her car caused by defendant as restitution as defendant cited to no law establishing that the trial court must limit a restitution award to the cost of a complaining witness's insurance deductible where the complaining witness has not filed an insurance claim and been reimbursed by her insurance company. The trial court did not err in awarding restitution to the victim that included the cost to replace the bumper of the victim's car after defendant pleaded guilty to damaging the victim's car's liftgate where the victim testified that in order to repair the damage caused by defendant to the liftgate, the bumper had to be replaced as well. The trial court committed harmless error in limiting defendant's cross-examination of the victim regarding the victim's prior inconsistent statements as to what damages defendant caused to the victim's car where, even if defendant did not cause the additional damage the victim claimed, defendant failed to challenge the victim's testimony that in order to repair the damage that defendant admitting to causing, the additional damage needed to be repaired as well.