Kelly, 479 U.S. at 51, 107 S.Ct. at 362. Although the restitution order at issue in Kelly conferred some benefit on the victim, the Court found that the award was generally imposed to further the penal goals of the state. The Court observed that “[u]nlike an obligation which arises out of a contractual, statutory or common law duty, here the obligation is rooted in the traditional responsibility of a state to protect its citizens by enforcing its criminal statutes and to rehabilitate an offender by imposing a criminal sanction intended for that purpose.” Based on this language in Kelly, courts have extended its holding to punitive obligations in non-criminal contexts, so long as the other statutory requirements are met. See, e.g., Whitehouse v. LaRoche, 277 F.3d 568, 573 (1st Cir.2002) (<HOLDING>) (citations omitted); State of Colorado ex rel
holding that aggravating circumstances in capital penalty proceedings are not separate penalties or offenses to which the protection against double jeopardy applies holding the mcarn exception requirefs that the acts complained of warrant the imposition of criminal penalties as opposed to mere civil penalties holding that  523a7 applies both to civil and criminal penalties if the particular penalty serves some punitive or rehabilitative governmental aim rather than a purely compensatory purpose holding compensatory and punitive damages constitute legal remedies holding that a claim for civil damages based on alleged violation of criminal statute under which criminal penalties result was properly dismissed because criminal violations are brought not in the name of the individual party but rather by and on behalf of the state of ohio or its subdivisions