State of Ohio v. Zachary C. Allen, Case No. 2018-0705
Tenth District Court of Appeals (Franklin County)

ISSUES:
- Is a bank that cashes a forged check and suffers a loss a "victim" under R.C. 2929.18?
- If a bank becomes a victim by cashing a forged check, can the defendant be convicted of forgery be ordered to pay restitution to the bank?

BACKGROUND:
In August 2016, Zachary Allen was indicted in Franklin County for seven counts of forgery and seven counts of possession of criminal tools. Allen cashed seven checks that he knew were counterfeit at four different banks. The checks were drawn from the accounts of two apartment complexes and one flooring service.