State v. Boettcher, 931 N.W.2d 376

Z.D.'s remote cabin in Minnesota was burglarized in December 2014 and later found destroyed by fire; trail-camera photos and a red Homelite generator linked the scene to Colton Boettcher.
Boettcher was tried by jury on first-degree arson and second-degree burglary; jury convicted him of burglary but deadlocked on arson; the State declined to retry arson.
At sentencing the district court reserved restitution and later ordered Boettcher to pay $81,931.79 for fire damage and related losses, relying on testimony that Boettcher started the fire and on camera evidence.
Boettcher challenged the restitution order, arguing the fire damage was not a predictable or direct consequence of the burglary and therefore not compensable under the statutory ‘‘result from the crime’’ standard.
The district court and Minnesota Court of Appeals upheld restitution after applying a ‘‘factual-relationship’’ test (time, victim, location) rather than a direct-causation standard.
The Minnesota Supreme Court granted review to decide the correct legal standard for ordering restitution for losses that occurred in connection with a crime of which the defendant was convicted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether restitution may be ordered for the cabin fire when defendant was convicted only of burglary (not arson), i.e., whether losses must be directly caused by the convicted offense or only factually related	State: restitution appropriate because the fire and burglary were factually related in time, victim, and location; loss is connected to the criminal episode	Boettcher: restitution requires direct causation or a natural consequence of the convicted crime; mere factual relationship is insufficient	The court held restitution requires direct causation (losses that "result from" the offense); the court of appeals erred by applying a mere factual-relationship test and remanded for reconsideration under the direct-causation standard

State v. Palubicki, 727 N.W.2d 662 (Minn. 2007) (adopts direct-result standard for restitution; losses must be direct result of the offense)
State v. Riggs, 865 N.W.2d 679 (Minn. 2015) (defines "result" as "follows naturally from" and reinforces direct-causation requirement)
Paroline v. United States, 572 U.S. 434 (2014) (construing "as a result of" to plainly suggest causation in restitution context)
State v. Nelson, 796 N.W.2d 343 (Minn. Ct. App. 2011) (articulated a factual-relationship formulation later disapproved by the Minnesota Supreme Court)