Hre v. State — Rental-Car Costs Excluded from Restitution
The Indiana Court of Appeals held that the criminal restitution statute does not authorize reimbursement for a victim’s rental-car expenses.
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Restitution
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Beedy — Wyoming Supreme Court Upholds Converse County Venue and Clothing Restitution
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.
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State v. Thompson — Civil Settlement Does Not Offset Criminal Restitution; “Person Within the State” Is Not an Element of False Pretenses
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.
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Robert Owen Lehman Foundation v. Israelitische Kultusgemeinde Wien — Court Confirms Title to Egon Schiele Portrait on Merits
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.
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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.