State v. Gonzales, 997 N.W.2d 97

Manuel Gonzales pleaded guilty to unlawful/unauthorized use of personal identifying information.
At sentencing the district court ordered $556 restitution for property taken from the victim’s vehicle: $500 cash, $45 for a replacement wallet, and $11 for replacement of an ATM card and driver’s license.
Gonzales appealed, arguing the ordered restitution was not directly related to the offense to which he pleaded guilty.
North Dakota law limits restitution to damages "directly related to the criminal offense" and expenses actually sustained as a direct result of the defendant’s criminal action.
The Supreme Court examined whether the district court’s restitution award was supported by evidence and properly tied to the conviction.
The Supreme Court held the district court misapplied the law and abused its discretion by ordering restitution for theft losses not causally connected to Gonzales’s conviction, and reversed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether restitution for items stolen from victim’s vehicle was "directly related" to Gonzales’s conviction for unauthorized use of personal identifying information	State asserted victim’s theft-related losses should be compensated via restitution	Gonzales argued theft losses were not causally or directly related to his conviction for misuse of identifying information	Reversed — restitution for the stolen property was not directly related to the offense; district court abused its discretion

State v. Harstad, 945 N.W.2d 265 (N.D. 2020) (explaining standard of review for restitution and abuse of discretion)
State v. Pippin, 496 N.W.2d 50 (N.D. 1993) (restitution requires an immediate and intimate causal connection between the criminal conduct and damages)
State v. Carson, 900 N.W.2d 41 (N.D. 2017) (restitution damages limited to losses directly related to the criminal offense)