Wyoming’s high court held that vulnerable-adult exploitation spanning two counties could be tried in Converse County and affirmed restitution for clothing made inaccessible by the crime.
The North Carolina Court of Appeals affirmed convictions for obtaining property by false pretenses and uttering forged instruments, holding that a victim’s prior civil settlement does not reduce the criminal restitution award, that a pending Wake County scheme involving the same TSA funds was properly admitted under Rule 404(b), and that “person within the State” is not an essential element of the offense because the Supreme Court’s longstanding four-element framework controls over Court of Appeals dicta.
The Fourth Department affirms on the merits that the Susan Zirkl Memorial Foundation Trust is the rightful owner of a 1917 Egon Schiele portrait, sidestepping laches and the newly enacted Holocaust Expropriated Art Recovery Act of 2025.
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.