State v. Reed
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The Supreme Court reversed the restitution order of the trial court to the extent that it ordered payment of C.C.'s attorney fees, holding that most of C.C.'s fees were not recoverable as criminal restitution.
Defendant was convicted of one count of voyeurism for using a mirror to look beneath the door of a bathroom being occupied by C.C. The trial court awarded C.C. restitution that included attorney fees she had incurred in retaining an attorney to represent her in the proceedings. The Supreme Court held (1) a victim's attorney fees are recoverable as criminal restitution but only when an attorney is reasonably necessary to remedy the harm caused by the criminal conduct; and (2) because the vast majority of the attorney fees sought by C.C. did not flow directly from Defendant's criminal conduct, those fees were indirect, consequential damages, and therefore, the court erred by awarding those fees as restitution.
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