State of Iowa v. Terran E. Roache

Summary

The Iowa Supreme Court reviewed a restitution order requiring Terran Roache to pay $1,900 for a stolen commercial-driver study guide. The court held that the Restatement (Third) of Torts scope-of-liability analysis applies to criminal restitution determinations, and that the $1,900 award was punitive and unsupported by substantial evidence. The court vacated the court of appeals decision and affirmed in part and reversed in part the district court judgment.

Holdings

1. The Restatement (Third) of Torts risk standard for scope of liability applies in criminal restitution determinations.
2. Roache's theft was the factual cause of Hagedon's loss of the study guide and resulting exposure to a charge for failing to return it.
3. The avoidable-consequences doctrine does not apply to reduce restitution for an intentional criminal act.
4. The $1,900 study-guide award was unsupported by substantial evidence and could not be included in criminal restitution.
5. The $1,900 fine was punitive and therefore excluded from pecuniary restitution under Iowa Code section 910.1(3).

Questions Presented

1. Whether the Restatement (Third) of Torts scope-of-liability analysis applies when determining criminal restitution for a victim's pecuniary damages.
2. Whether Roache's theft was the factual cause of Hagedon's exposure to the $1,900 study-guide charge.
3. Whether the $1,900 charge was within the scope of liability and recoverable as pecuniary damages in restitution.
4. Whether the State presented substantial evidence supporting the amount of the $1,900 restitution award.
5. Whether the $1,900 charge constituted prohibited punitive damages or an unenforceable contractual penalty.

Disposition

other