In Re Colson D., 1 CA-JV 20-0399

In April 2019, then-17-year-old Colson D. drove friends through Queen Creek neighborhoods over four nights, during which they egged, kicked, or shot BB guns at houses and vehicles belonging to ~150 victims.
Colson pled delinquent to one count of criminal damage and stipulated in his plea to pay restitution to all victims described in 145 Maricopa County Sheriff's incident reports; he also agreed to a specified $1,806.14 restitution for three named victims.
At an October 2020 restitution hearing Colson stipulated to additional restitution for 12 victims and contested five specific claims (C.V., A.M., J.J., D.Q., and Progressive Insurance).
The juvenile court awarded restitution to the five contested victims: C.V. $5,133.59 (including medical and lost wages), A.M. $1,030.50, J.J. $139.50, D.Q. $2,180 (including $2,000 to paint the house), and Progressive $1,618.52.
Colson appealed, arguing (1) insufficient evidence that he caused the Five Victims’ economic losses and (2) that awarding $2,000 to paint D.Q.’s entire house made the victim more than whole.
The Court of Appeals affirmed, relying on Colson’s plea stipulation to restitution, the incident reports, and legal principles governing restitution and causation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Causation for Five Victims’ losses	Restitution proper because Colson pled delinquent and stipulated to pay restitution for losses described in the 145 incident reports documenting egging, kicking, or BB damage	Colson argued insufficient evidence that he or his codefendant caused the economic losses for the five contested victims	Affirmed: plea stipulation + incident reports provide reasonable inference of causation; restitution bears a reasonable relationship to victims’ losses
D.Q.’s painting award (whole-house paint)	Restitution may include expenses to restore victim’s equanimity; D.Q. testified he had to paint the whole house, not just the damaged portion	Colson argued painting the entire house made D.Q. more than whole because only 15–20% of the front was damaged	Affirmed: trial court acted within broad discretion; whole-house painting reasonably flowed from the offense to restore equanimity and did not make victim more than whole

In re Andrew C., 215 Ariz. 366 (App. 2007) (defines elements for permissible restitution)
In re William L., 211 Ariz. 236 (App. 2005) (standard of review and requirement that restitution reasonably relate to loss)
Hoffman v. Chandler ex rel. County of Pima, 231 Ariz. 362 (App. 2013) (restitution pursuant to plea agreement may be entered even if amount contested)
Maricopa Cnty. Juv. Action No. JV-132905, 186 Ariz. 607 (App. 1996) (sufficient inference of causation where juvenile stipulated to restitution and victim documented damage)
State v. Quijada, 246 Ariz. 356 (App. 2019) (courts may award restitution for expenses incurred to restore victim's equanimity)
State v. Baltzell, 175 Ariz. 437 (App. 1992) (broad view of recoverable restitutionary expenses)
State v. Brady, 169 Ariz. 447 (App. 1991) (restitution may include efforts to restore victim's equanimity)
In re Andrew A., 203 Ariz. 585 (App. 2002) (trial court may discredit juvenile's testimony and infer responsibility)