State of Iowa v. Jonathan Kay Davis, 15-1223

Defendant Jonathan Davis was convicted of first-offense OWI (marijuana) after a crash; this restitution order arises from that conviction.
At a restitution hearing the victim (Miller) claimed damages to his truck, 9000-pound trailer, and several antique washing machines being transported.
The district court found Davis’s intoxicated, reckless operation proximately caused the collision, the trailer to break loose and flip, and damage to the machines; it ordered $14,000 in restitution (net amount after amendment).
Evidence at the hearing included the victim’s testimony about values and two emailed repair/replace estimates prepared by third parties who had viewed photos but not inspected the machines.
The district court discredited the victim’s valuation of his labor/time and relied heavily on the emailed estimates; the court found gaps in documentation for labor rates, salvage value, and insurance offsets.
On appeal the court reviewed whether causation and the amount of restitution were supported by substantial evidence and whether hearsay improperly supported the damages award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Causation: whether Davis’s OWI was the proximate cause of victim’s property damage	State: the manner of operating while intoxicated proximately caused the crash and resulting damage	Davis: the court improperly referenced reckless driving and the OWI conviction may not be the proximate cause	Held: Affirmed causation—substantial evidence showed intoxication led to reckless operation that proximately caused damages
Admissibility/Amount: whether evidence supported $14,000 restitution	State: emailed estimates and victim’s testimony establish damages amount	Davis: estimates were hearsay/speculative and victim’s valuations were unreliable; amount unsupported	Held: Reversed as to amount—only $414.75 (parts actually purchased) supported by substantial evidence; emailed estimates speculative/hearsay insufficient to sustain $14,000 award

State v. Bonstetter, 637 N.W.2d 161 (Iowa 2001) (appellate deference to district court factual findings if supported by substantial evidence)
State v. Starkey, 437 N.W.2d 573 (Iowa 1989) (causation analysis distinguishing offenses when damages stem from a different criminal act)
State v. Ihde, 532 N.W.2d 827 (Iowa Ct. App. 1995) (restitution requires causal connection between criminal act and victim’s injury)
Papenheim v. Lovell, 530 N.W.2d 668 (Iowa 1995) (damages for harm to chattels include difference in value or reasonable cost of repair)
State v. Holmberg, 449 N.W.2d 376 (Iowa 1989) (causal connection requirement for restitution)
State v. Savage, 288 N.W.2d 502 (Iowa 1980) (owner may testify to actual value of property without market-value expertise)