State v. Policano

2025 Ohio 2459
CourtOhio Court of Appeals
DecidedJuly 11, 2025
DocketC-240503
StatusPublished

This text of 2025 Ohio 2459 (State v. Policano) 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. Policano, 2025 Ohio 2459 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Policano, 2025-Ohio-2459.]

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

STATE OF OHIO, : APPEAL NO. C-240503 TRIAL NO. C/24/CRB/2949/A Plaintiff-Appellee, :

vs. : JUDGMENT ENTRY TANYA POLICANO, :

Defendant-Appellant. :

This cause was heard upon the appeal, the record, and the briefs. The judgment of the trial court is affirmed for the reasons set forth in the Opinion filed this date. Further, the court holds that there were reasonable grounds for this appeal, allows no penalty, and orders that costs are taxed under App.R. 24. The court further orders that 1) a copy of this Judgment with a copy of the Opinion attached constitutes the mandate, and 2) the mandate be sent to the trial court for execution under App.R. 27.

To the clerk: Enter upon the journal of the court on 7/11/2025 per order of the court.

By:_______________________ Administrative Judge [Cite as State v. Policano, 2025-Ohio-2459.]

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

STATE OF OHIO, : APPEAL NO. C-240503 TRIAL NO. C/24/CRB/2949/A Plaintiff-Appellee, :

vs. : OPINION TANYA POLICANO, :

Criminal Appeal From: Hamilton County Municipal Court

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: July 11, 2025

Connie M. Pillich, Hamilton County Prosecuting Attorney, and Ronald W. Springman, Jr., Assistant Prosecuting Attorney, for Plaintiff-Appellee,

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

BOCK, Judge.

{¶1} Defendant-appellant Tayna Policano crossed neighborly and legal

boundaries when she damaged her neighbor’s front door. The issue in this appeal is

how much Policano must pay in restitution. Specifically, we consider how trial courts

may measure the value of property when awarding restitution.

{¶2} We hold that the trial court did not abuse its discretion when it relied

on the replacement cost of the damaged property to determine the victim’s economic

loss and award restitution when the property’s value before the damage was not

readily discernable. And we hold that the trial court did not abuse its discretion when

it relied on a higher-priced estimate as a basis for a restitution award for damaged

property where the lower-priced estimate failed to account for the full scope of

replacing the damaged property.

{¶3} We overrule the assignment of error and affirm the restitution award.

I. Factual and Procedural History

{¶4} Policano pleaded guilty to criminal damaging under R.C. 2909.06(A)(1)

for damaging her neighbor’s “solid wood” front door.

{¶5} At the restitution hearing, Policano’s neighbor explained that her house

was constructed in 1966, and she moved into the house in 2017. Her neighbor

suspected that the front door is original to the house.

{¶6} Policano’s neighbor contacted five contractors for repair estimates. But

multiple contractors remarked that the damage was beyond repair and the door

needed to be replaced. Of those five contractors, two returned formal estimates to

replace the front door.

{¶7} Relevant here, Hattery and Rowan Construction, LLC, returned a

$4,663.60 estimate to replace the door: $3,288.60 for a “Craftsman Knotty Alder 7”

3 OHIO FIRST DISTRICT COURT OF APPEALS

pre-hung door and $1,375 for labor. Policano’s neighbor also found a “Craftsman

Knotty Alder” pre-hung door listed on Home Depot’s website for $1,818. But, the State

explained, Home Depot’s price excluded labor and fixtures.

{¶8} The trial court imposed a suspended 90-day jail sentence and two years

of community control and ordered Policano to pay $4,663 in restitution.

II. Analysis

{¶9} On appeal, Policano challenges two aspects of the trial court’s

restitution order. First, she argues that the trial court must limit restitution to the

value of the property as it existed before the offense. Second, she argues that the trial

court’s restitution award should have reflected the cost of the door at Home Depot.

Unconvinced, we affirm the restitution award.

{¶10} As a financial sanction for a misdemeanor offense, a sentencing court

may award restitution to a crime victim who bore an economic loss as a result of the

crime. R.C. 2929.28(A)(1). If restitution is disputed, the sentencing court must hold

an evidentiary hearing and “determine the amount of full restitution by a

preponderance of the evidence.” Id.

{¶11} We review the sentencing court’s restitution award for an abuse of

discretion. State v. Palmer, 2024-Ohio-1445, ¶ 17 (1st Dist.); see State v. Nelson, 2024-

Ohio-1773, ¶ 10 (1st Dist.). A trial court acts within its discretion when its restitution

award is supported by competent and credible evidence. Id., quoting State v. Betley,

2018-Ohio-2516, ¶ 13 (8th Dist.).

A. The trial court reasonably relied on the door’s replacement cost

{¶12} First, Policano argues that the restitution award must reflect the value

of her neighbor’s front door as it existed before it was damaged.

4 OHIO FIRST DISTRICT COURT OF APPEALS

{¶13} Ohio’s sentencing statutes limit restitution amounts to the victim’s

economic loss. Id. Economic loss includes “any economic detriment suffered by a

victim as a direct and proximate result of the commission of the offense and includes

. . . any property loss . . . incurred as a result of the commission of the offense.” R.C.

2929.01(L). Before a trial court may order restitution, the economic loss “‘must be

established to a reasonable degree of certainty.’” State v. Macquarrie, 2009-Ohio-

2182, ¶ 7 (2d Dist.), quoting State v. Golar, 2003-Ohio-5861, ¶ 12 (11th Dist.). And the

restitution amount must be reasonably related to the victim’s actual loss. In re A.B.,

2020-Ohio-4273, ¶ 8 (1st Dist.), quoting In re M.N., 2017-Ohio-7302, ¶ 8 (1st Dist.).

{¶14} Policano contends that the trial court should have followed this court’s

restitution analysis in Palmer, 2024-Ohio-1445 (1st Dist.). In Palmer, we explained

that, for “vehicles, damage may be determined by demonstrating the reasonable cost

to repair the vehicle.” Id. at ¶ 20. But “when a vehicle has been totally destroyed, ‘“the

measure of damages is its reasonable market value immediately before destruction.”’”

State v. Moore, 2023-Ohio-3318, ¶ 12 (1st Dist.), quoting State v. Caldwell, 2023-

Ohio-355, ¶ 17 (4th Dist.), quoting Falter v. Toledo, 169 Ohio St. 238, 240 (1959); see

State v. Mazan, 2023-Ohio-4385, ¶ 17 (1st Dist.) (“The victim’s car was totaled, so the

economic loss suffered by the victim was the fair market value of the vehicle that was

destroyed.”). The fair market value is “[t]he price that a seller is willing to accept and

a buyer is willing to pay on the open market and in an arm’s-length transaction.”

Black’s Law Dictionary (8th Ed. 2004).

{¶15} But the rule that we recited in Palmer has been described as “specific

guidance regarding the right to recover for damage to an automobile.” Karr v. Salido,

2024-Ohio-1141, ¶ 33 (10th Dist.). Of course, the “market value” is considered “the

standard which the courts insist on as a measure of direct property loss.” Bishop v. E.

5 OHIO FIRST DISTRICT COURT OF APPEALS

Ohio Gas Co., 143 Ohio St. 541, 546 (1944). Yet, “market value. . .

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2025 Ohio 2459, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-policano-ohioctapp-2025.