State v. Palmer

2024 Ohio 1445, 241 N.E.3d 905
CourtOhio Court of Appeals
DecidedApril 17, 2024
DocketC-230412
StatusPublished
Cited by5 cases

This text of 2024 Ohio 1445 (State v. Palmer) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Palmer, 2024 Ohio 1445, 241 N.E.3d 905 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Palmer, 2024-Ohio-1445.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

STATE OF OHIO, : APPEAL NO. C-230412 TRIAL NO. 23TRD-1318A Plaintiff-Appellee, : O P I N I O N. vs. :

EDYN PALMER, :

Defendant-Appellant. :

Criminal Appeal From: Hamilton County Municipal Court

Judgment Appealed From Is: Reversed and Cause Remanded

Date of Judgment Entry on Appeal: April 17, 2024

Emily Smart Woerner, City Solicitor, William T. Horsely, Chief Prosecuting Attorney, Victoria Gooder and Danielle Ferris, Assistant Prosecuting Attorneys, for Plaintiff- Appellee,

Raymond T. Faller, Hamilton County Public Defender, and Krista Gieske, Assistant Public Defender, for Defendant-Appellant. OHIO FIRST DISTRICT COURT OF APPEALS

KINSLEY, JUDGE.

{¶1} When one driver hits another and causes damage to a car, the law often

permits an award of restitution. But restitution is not automatic. The offending driver

may request a hearing and has a right to due process that includes the meaningful

opportunity to be heard, both as to the value of damages caused to the car and as to

whether restitution should be awarded at all. What does it mean to have such an

opportunity? Is it enough to simply inspect a computer printout that estimates a car’s

value or a mechanic’s receipt that estimates the costs of needed repairs? Or does due

process require that a driver be able to subpoena a witness to answer questions about

the status of a damaged car when restitution is contested? As we hold today, the

answer to these questions is: “it depends.”

{¶2} After entering no-contest pleas and being found guilty of failure to

maintain reasonable control in violation of R.C. 4511.202 and the amended charge of

reckless operation of a vehicle in violation of Cincinnati Municipal Code 506-6,

defendant-appellant Edyn Palmer appeals the judgment of the trial court ordering her

to pay $3,233 in restitution. For the reasons that follow, we reverse the trial court’s

order as to the amount of restitution and remand the matter to the trial court to hold

an evidentiary hearing on that question.

Factual and Procedural Background

{¶3} On July 24, 2022, Edyn Palmer lost control of her vehicle and struck the

vehicle of Jamie Adams. After colliding with Adams’s vehicle, Palmer fled the scene

of the accident and failed to provide her driver’s license and insurance information.

As a result, Palmer was charged with failure to maintain reasonable control in

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violation of R.C. 4511.202, a minor misdemeanor, and leaving the scene of an accident

in violation of R.C. 4549.02, a misdemeanor of the first degree.

{¶4} On April 4, 2023, Palmer entered no-contest pleas to the reasonable-

control charge and an amended charge of reckless operation of a vehicle in violation

of Cincinnati Municipal Code 506-6, a misdemeanor of the fourth degree. The state

briefly explained the facts of the case on the record, generally describing the accident

without mentioning the specific damage that was caused to Adams’s car. The trial

court found Palmer guilty of both charges.

{¶5} The trial court then allowed both sides to present arguments as to the

appropriate sentence. Defense counsel acknowledged that restitution was owed to

Adams, but requested a restitution hearing, along with “reputable” information, to

establish the amount. The state agreed that the case should be set for a restitution

hearing, because Adams had not brought a receipt for the damage to her vehicle to

court.

{¶6} The trial court then asked Adams, who was present in the courtroom, if

she had anything she wanted to add. Adams stated, “[W]hen we heard from the

mechanic they pretty much said unless you have a judge tell you to get a receipt we

won’t write you one[.]” When the trial court asked Adams if the vehicle was totaled,

she responded, “[I]t appears they estimated it’s probably about three for the car, and

it would be four for the damages, so they totaled it.” In response, the trial court issued

an order requiring “Ron’s Complete Auto Body,” the name provided by Adams as the

mechanic, to provide a receipt that Adams could present as evidence of the repair

amount for the car.

3 OHIO FIRST DISTRICT COURT OF APPEALS

{¶7} The trial court also asked defense counsel if the Kelley Blue Book (“Blue

Book”) value of the car would be acceptable, if provided by Adams. Defense counsel

responded, “The concern I have here is, Your Honor, this happened in July, and from

what I understand the prosecuting witness just took the car to a mechanic this week.

* * * So - - I mean, like I said, I have concerns as far as the dollar amount.”

{¶8} The matter was continued until May 30, 2023, for a restitution hearing

on the reckless-driving charge. On the reasonable-control charge, the trial court

sentenced Palmer to no fine, and that charge was fully disposed.

{¶9} At the May 30th hearing, Adams did not appear. Instead, the state and

defense counsel apprised the court of the status of the restitution evidence. During

the hearing, the prosecutor indicated that Adams had submitted a repair estimate and

a Blue Book printout with an estimated value range. Defense counsel questioned

whether Adams had car insurance and the deductible of that insurance policy, noting

that the police report indicated that Adams had insurance.1 The trial court continued

the matter to July 17, 2023, for further investigation of the insurance matter.

{¶10} At the July 17, 2023 hearing, defense counsel took issue with the Blue

Book estimated value range because it was for the replacement of the vehicle, and

Palmer reportedly had evidence of Adams recently driving the vehicle. Defense

counsel also took issue with the fact that Adams was not present, although subpoenaed

by defense counsel. The prosecution argued that the repair estimate and Blue Book

printout were sufficient evidence to prove the restitution amount. In response,

defense counsel questioned the authenticity of the estimate, noting the lack of self-

1 If Adams in fact maintained an insurance policy that provided coverage, less a deductible, for repairs to her vehicle, then precedent indicates the amount of restitution should be set at the amount of the deductible, not the amount of the damage. See, e.g., State v. Nickens, 8th Dist. Cuyahoga No. 104670, 2017-Ohio-1448.

4 OHIO FIRST DISTRICT COURT OF APPEALS

authenticating information. Importantly, the state agreed that it could not

authenticate the document without a witness present. As a result, the trial court

explained that it was “not ordering restitution based on” the state’s lack of an

authenticating witness and continued the hearing to allow the state to secure Adams’s

testimony.

{¶11} The final hearing was held on July 31, 2023. Again, Adams was not

present. Through the prosecutor, the state submitted two exhibits as its sole evidence

in support of restitution. As Exhibit 1, the state submitted a Blue Book value range

printout. The exhibit reflected a private-party range of $2,540 to $3,925, with a

private-party value of $3,233. It indicated these values were valid as of April 7, 2023.

It did not otherwise indicate the make, model, age, or condition of the vehicle, the

source of the values, or who created the printout. As Exhibit 2, the state submitted a

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Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 1445, 241 N.E.3d 905, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-palmer-ohioctapp-2024.