The court reasoned that because of Keyes's stipulated alcohol problem, consecutive maximum sentences were appropriate in order to rehabilitate and prevent him from engaging in future alcohol-related crimes. {¶ 14} Keyes relies in part on State v. Littlefield (Feb. 6, 2003), Washington App. No. 02CA19, 2003-Ohio-863, in support of his contention that the court failed to conduct a proper consistency analysis. In Littlefield, we concluded that "a proportionality analysis that looks solely to the defendant's criminal history is legally flawed."
{¶ 38} In ordering restitution, the trial court must limit its award to "the actual economic loss caused by the crime for which the offender was convicted." State v. Littlefield (Feb. 6, 2003), 4th Dist. No. 02CA19 (emphasis supplied), citing State v. Hafer, 144 Ohio App.3d 345, 348, 2001-Ohio-2412, 760 N.E.2d 56; see, also, State v. Hooks (2000), 135 Ohio App.3d 746, 748, 735 N.E.2d 523. As noted by the court in Littlefield, the corollary of this principle is that an "offender cannot be ordered to pay restitution for damage arising from a crime of which he is not convicted."
Finally, the court must find one of the three enumerated circumstances in R.C. 2929.14(E)(4)(a) through (c). State v. Littlefield, 4th Dist. No. 02CA19, 2003 Ohio 863. {¶ 11} Pursuant to R.C. 2929.14(E)(4), the foregoing three findings must be made before the court can impose consecutive sentences.