State v. Curwick — Medical Evidence Plus UOVC Documentation Suffices to Establish Restitution Causation for Victim’s Mother
The Utah Court of Appeals affirmed a restitution order for an aggravated kidnapping victim’s mother, holding that a medical form attributing her PTSD to the crime, her own written statements, and a UOVC restitution specialist’s declaration—taken together—provided sufficient evidence of proximate causation for her lost wages.