State v. Corbus, 150 Idaho 599

May 7, 2006: Corbus drove at ~60 mph in a 35 mph zone; police pursued as he accelerated, turned off headlights, and reached >100 mph.
Passenger in front seat jumped out during the chase, was injured and hospitalized.
Corbus pled guilty to reckless driving and entered a conditional plea to felony eluding; plea agreement provided restitution for the passenger’s injuries and dismissal of driving-without-privileges charge.
District court ordered restitution to be determined at a hearing; Corbus argued no causal link between conduct and injuries; no evidence on passenger’s motive at restitution.
The district court ordered $18,203.67 restitution, finding a sufficient causal connection; Court of Appeals affirmed; petition for review granted and later resumed after Lampien decision.
This appeal addresses whether substantial evidence supports the causal connection between Corbus’ conduct and the passenger’s injuries (actual and proximate causation).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is substantial evidence of actual causation.	Corbus argues lack of direct evidence of motive; passenger’s motive irrelevant to actual causation.	Corbus contends no causal link between his acts and injuries.	Yes; substantial evidence shows but-for Corbus’ conduct would have caused injuries.
Whether there is substantial evidence of proximate causation.	Corbus' dangerous driving foreseeably caused the passenger to jump for safety.	Jumping was not a foreseeable reaction; lack of motive evidence weakens foreseeability.	Yes; injuries were reasonably foreseeable given dangerous conduct.
Whether the passenger’s act was an intervening, superseding cause.	Passenger’s jump was not an extraordinary, unforeseeable act and did not break the causal chain.	Passenger’s action could be seen as an intervening cause.	No; no superseding intervening cause; Corbus remains liable.

Lampien v. State, 148 Idaho 367 (Idaho 2009) (frames causation analysis for restitution (actual and proximate))
Cramer v. Slater, 146 Idaho 868 (Idaho 2009) (causation; proximate cause standard in restitution)
Lombard v. State, 149 Idaho 819 (Idaho Ct.App.2010) (substantial evidence standard on restitution findings)
State v. Coffin, 104 Idaho 543 (Idaho 1983) (guilty plea as judicial admission of facts)
State v. Shafer, 144 Idaho 370 (Idaho Ct.App.2007) (distinction where victim’s injuries result from act versus accident; not controlling here)