Com. v. Stoops, R., 290 A.3d 721

On April 17, 2019, Stoops led police on a vehicle chase through Waynesboro; he ultimately stopped in an alley where his car was boxed in by three police cruisers.
As a passenger exited Stoops’s vehicle, the car lurched forward with brake lights cycling; one cruiser struck Stoops’s vehicle from behind and Stoops’s car then struck a cruiser ahead.
Stoops pleaded guilty to fleeing and two counts of recklessly endangering another person and was sentenced to 4–8 years’ incarceration; the court also ordered restitution for police-vehicle damage.
Trial court originally ordered $12,584.77 in restitution; the Commonwealth and Stoops agreed that if restitution were proper the amount should be reduced to $9,691.85, which the court adopted.
Stoops moved to vacate restitution, arguing the police’s intentional ramming was an independent intervening act severing causation; the trial court denied the motion and Stoops appealed.
The Superior Court affirmed, holding that Stoops’s flight was the but‑for cause of the vehicle damage and that the police action did not break the causal chain required for restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether restitution for police-vehicle damage was payable because the damage was a "direct result" of Stoops’s crime	Stoops: he had stopped, was boxed in, and a passenger exited; police intentionally rammed his car, so their conduct was an independent, intervening cause making restitution improper	Trial court/Commonwealth: Stoops’s initial flight set events in motion; under the but‑for test the damage would not have occurred but for his criminal flight, so restitution is proper	Affirmed: restitution lawful because Stoops’s flight was the but‑for cause of the damage; police contact did not break the causal chain

Commonwealth v. Stradley, 50 A.3d 769 (Pa. Super. 2012) (procedural rule allowing modification of restitution by trial court)
Commonwealth v. Lekka, 210 A.3d 343 (Pa. Super. 2019) (plenary, de novo review of legality of sentence)
Commonwealth v. Zrncic, 167 A.3d 149 (Pa. Super. 2017) (restitution requires loss that flows from conduct forming basis of crime)
Commonwealth v. Barger, 956 A.2d 458 (Pa. Super. 2008) (en banc) (requires a direct causal connection between crime and loss)
Commonwealth v. Poplawski, 158 A.3d 671 (Pa. Super. 2017) (adopts but‑for test for restitution causation)
Commonwealth v. Weir, 201 A.3d 163 (Pa. Super. 2018) (explains but‑for inquiry for restitution causation)