State v. Blake, 517 P.3d 414

On Feb 12, 2019 Blake shot at his ex-girlfriend’s car and shot her new boyfriend in the arm; the victim underwent surgery to remove a bullet and repair his arm.
Blake pleaded guilty to reduced charges (including aggravated assault) and the court imposed concurrent prison terms, $500 restitution for car damage, and left restitution open for additional claims.
The State moved to amend restitution to include $36,701.56 that the Utah Office for Victims of Crime (UOVC) allegedly paid for the victim’s medical bills, attaching a redacted payment list showing seven payments for twenty-two claims dated Feb 12–14, 2019 labeled only as “Medical” or “Medical Facility.”
Two UOVC representatives described standard claim-review procedures (claims analysts check dates and codes to verify crime-relatedness) but neither had personal knowledge of the specific payments and the underlying invoices, providers, and procedure/diagnostic codes were not submitted.
The district court relied on the payment list and UOVC’s procedures, concluded the medical bills arose from the crime, and ordered complete restitution of $36,701.56 and court-ordered restitution of $18,350.78; Blake appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion by ordering restitution for UOVC-paid medical charges when the State did not tie those payments to Blake’s criminal conduct	The UOVC payment list plus testimony about UOVC’s standard review procedures is proof enough that the payments are crime-related; the court may reasonably estimate losses	The redacted, generic payment list lacks provider/service detail and causal linkage; the State failed to present evidence allowing the court to independently find proximate cause and cannot delegate that determination to UOVC	Reversed: evidence insufficient. Court may not rely solely on UOVC’s conclusory determinations; State must produce underlying records or other evidence to permit the court’s independent proximate-cause finding

State v. Ogden, 416 P.3d 1132 (Utah 2018) (establishes proximate-cause standard for restitution and that amounts must rest on a sufficient evidentiary basis even if approximated)
State v. Watson, 485 P.3d 946 (Utah Ct. App. 2021) (UOVC’s internal determination of crime-relatedness cannot substitute for the court’s independent proximate-cause finding; generic therapy/medical lists insufficient)
State v. Oliver, 427 P.3d 495 (Utah Ct. App. 2018) (discusses allocation of burden of proof for restitution claims)