State v. Cameron David Harer, 369 P.3d 316

Defendant Cameron David Harer pled guilty to possession with intent to deliver; possession charge and enhancement were dismissed.
At sentencing the State sought $410 restitution under I.C. § 37-2732(k): $200 for lab costs and $210 for prosecutor time (regular salary for hours spent).
The district court awarded $200 (lab) but denied the $210 prosecution cost claim.
District court rationale: prosecutor salary is not an "economic loss" because salary would be paid regardless; case was a "routine" drug case so prosecution costs should remain a governmental burden.
The State appealed, arguing the court read requirements into I.C. § 37-2732(k) (requiring proof of additional economic loss and that the case be "different than the standard criminal case").

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether I.C. § 37-2732(k) permits restitution for a prosecutor’s regular salary without additional proof of "economic loss" beyond salary itself	The statute expressly includes "regular salaries of employees" as recoverable costs; State provided hourly rate and hours, satisfying the statute	District court: salary is not an out-of-pocket economic loss because it would have been paid anyway; State needed to show additional economic loss	Reversed: prosecutor’s regular salary for time spent is the statutory economic loss; court erred by requiring more proof before recognizing loss
Whether trial court may categorically exclude "routine" or "standard" cases from consideration for prosecution-cost restitution	State: statute is discretionary but does not limit awards only to extraordinary cases; no statutory basis to require case be "different"	District court: prosecution costs are ordinarily government burden; restitution should be limited to non-routine cases	Reversed: court may consider case complexity as a factor but cannot foreclose restitution for an entire category of "routine" cases or impose a threshold showing that a case is "different"

State v. Weaver, 158 Idaho 167, 345 P.3d 226 (Ct. App. 2014) (guidance that § 37-2732(k) awards are discretionary and general restitution statute informs procedure)
State v. Cardoza, 155 Idaho 889, 318 P.3d 658 (Ct. App. 2014) (discretionary nature of restitution awards under related statutes)
State v. Gomez, 153 Idaho 253, 281 P.3d 90 (2012) (use of general restitution principles to interpret specialized restitution provisions)
State v. Mosqueda, 150 Idaho 830, 252 P.3d 563 (Ct. App. 2010) (trial court may deny restitution if claimed costs are tenuously connected to conviction or unreasonably incurred)
State v. Anderson, 152 Idaho 21, 266 P.3d 496 (2011) (trial court must correctly perceive scope of its discretion when awarding restitution)
State v. Hedger, 115 Idaho 598, 768 P.2d 1331 (1989) (appellate review framework for discretionary decisions)