State v. Christy

State v. Pumphrey provides that a court may award restitution for expenses incurred by a victim in implementing security measures in response to a defendant’s crimes, if there is evidence sufficient to support a finding that Defendant’s criminal activities were a “but for” cause of the expenses that the victim incurred.

Defendant appealed a judgment from the trial court ordering restitution after Defendant pleaded guilty to burglary, theft, and criminal mischief. Defendant assigned error to the portion of the restitution award for the security system, as well as to the award of court-appointed attorney fees. The Court held that a trial court may award restitution for expenses incurred by a victim in implementing security measures in response to a defendant’s crimes, if there is evidence sufficient to support a finding that Defendant’s criminal activities were a “but for” cause of the expenses that the victim incurred, and any other criteria for an award of restitution is satisfied. State v. Pumphrey, 266 Or App 729, 733 (2014). Affirmed.