Does Amended Restitution Law Allow Court to Order Reimbursement to State Crime Victims Fund?
State of Ohio v. Charles W. Bartholomew, Case no. 2007-1462 3rd District Court of Appeals (Crawford County) ISSUE: Did 2004 legislative amendments to Ohio’s criminal restitution law eliminate the authority of trial courts to include in an offender’s sentence a requirement that he or she reimburse the state’s Victims of Crime Reparations Fund for payments the fund has made to a victim of the offender’s crime? BACKGROUND: In March 2006 Charles Bartholomew entered a guilty plea and was convicted of raping his 12-year-old daughter. In addition to a prison term and other sanctions, the Crawford County Court of Common Pleas included in his sentence an order that Bartholomew reimburse the state’s Crime Victims Fund for $426 the fund had previously paid to his wife to cover the costs of obtaining psychiatric counseling for their daughter. Bartholomew appealed his conviction and sentence. On review, the 3rd District Court of Appeals affirmed his conviction and prison term, but vacated the resti