Martinez v. People
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The Supreme Court of the State of Colorado affirmed a lower court's restitution order, ruling that the defendant was the proximate cause of the victim's pecuniary loss. The defendant, Arnold Roman Martinez, had stolen a bicycle and was pursued by the bicycle's owner in a car. The car was damaged when the owner cut off Martinez, causing him to crash into the car. The district court ordered Martinez to pay over $2,000 in restitution for the damage to the car.
On appeal, Martinez challenged the order, asserting that he did not proximately cause the damage to the car. The Supreme Court of the State of Colorado ruled that the standard for reviewing a district court's determination of proximate cause for criminal restitution is clear error, not the abuse-of-discretion standard used by the lower court. The Supreme Court found that the district court did not clearly err in determining that Martinez's theft was the proximate cause of the damage to the car. Therefore, the Supreme Court affirmed the restitution order on different grounds.
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