Brittany Michelle Barrett v. State, 12-15-00147-CR

Barrett challenged restitution awards after guilty pleas to aggravated assault with a deadly weapon in two Smith County cases.
Trial court deferred guilt, placed Barrett on ten-year community supervision, and ordered restitution to victims pending a post-sentence investigation.
Post-sentence investigation (PSI) filed Oct. 9, 2012, showing itemized medical bills for victims; restitution amounts amended in Nov. 2012 orders.
Final adjudication occurred May 12, 2015, revoking supervision and ordering new restitution amounts to ETMC/ETMC-EMS and Trinity Mother Francis Hospital.
The State argues PSI provides sufficient factual basis; Barrett forfeited objections to third-party restitution and argues only legal sufficiency of amounts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the restitution award supported by a sufficient factual basis?	Barrett argues insufficient factual basis for the amounts.	State argues PSI's itemized medical bills provide the basis for awards.	Yes; the record shows a sufficient factual basis for restitution.

Burt v. State, 445 S.W.3d 752 (Tex. Crim. App. 2014) (restitution must be supported by a factual basis in the record)
Cartwright v. State, 605 S.W.2d 287 (Tex. Crim. App. 1980) (abuse of discretion standard for restitution orders)
Jones v. State, 713 S.W.2d 796 (Tex. App.—Tyler 1986, no pet.) (PSI/factual basis can support restitution to victims)
Idowu v. State, 73 S.W.3d 918 (Tex. Crim. App. 2002) (forfeiture rule for challenges to restitution on appeal)
Campbell v. State, 5 S.W.3d 693 (Tex. Crim. App. 1999) (discussion of restitution standards)