State v. Hedgcock, 443 P.3d 1288

In a 2011 divorce decree Hedgcock agreed (via stipulation) to pay $701/month child support; ORS was joined but did not modify the order. Hedgcock paid only $780 total during the charged period (2011–Jan 2016).
In Jan 2016 Hedgcock was charged with criminal nonsupport based on an alleged arrearage (with interest) exceeding $10,000; he pled no contest to one count in exchange for a sentencing recommendation and a 402 reduction contingent on payment of restitution.
At trial the district court granted the State’s motion in limine excluding evidence that Hedgcock disputed the underlying child-support amount because he had not filed a petition to modify the Decree in the domestic court.
At sentencing the parties stipulated to a restitution figure of $51,883; the district court entered a stipulated sentencing order awarding restitution but did not specify whether that amount constituted “complete restitution,” “court-ordered restitution,” or both.
Hedgcock appealed, arguing (1) the court failed to make separate findings for complete restitution and court-ordered restitution as required by the Crime Victims Restitution Act and controlling precedent, and (2) the court abused its discretion by refusing to consider whether the domestic decree should have been modified during the charged period.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hedgcock)	Held
Whether the district court complied with the Restitution Act by making separate findings for complete restitution and court-ordered restitution	The restitution amount in the sentencing order reflects court-ordered restitution; the stipulated figure was appropriate and enforceable	The court conflated complete and court-ordered restitution and failed to make the distinct findings required by statute and precedent	Court: Error — vacated and remanded because the district court did not make separate findings; failure was plain and potentially harmful
Whether Hedgcock could force the criminal court to retroactively consider modification of the divorce decree (i.e., decrease arrears based on unfiled petitions to modify)	The criminal court properly treated the Decree as final; modification is a domestic-court matter; the charged arrearage was a final judgment absent a timely modification petition	Hedgcock argued the court should consider that the support amount was imputed/higher than actual income and could have been modified earlier, reducing restitution	Court: No abuse of discretion in refusing to consider retroactive modification; a petition to modify would only affect obligations prospectively (or from petition date) and Hedgcock never filed one

State v. Mooers, 424 P.3d 1 (Utah 2017) (distinguishes complete restitution from court-ordered restitution and requires separate findings)
State v. Laycock, 214 P.3d 104 (Utah 2009) (interprets Restitution Act to require courts to determine restitution types and consider statutory factors)
State v. Johnson, 416 P.3d 443 (Utah 2017) (plain-error review framework for unpreserved sentencing/restitution errors)