State v. Jent, 2013 MT 93

Jent pleaded guilty to aggravated assault of Cadorette and was ordered to pay restitution, including medical expenses of $19,866.69 arising from a suicide attempt after the offense.
Cadorette underwent medical treatment for injuries and later a suicide attempt occurred two days after Jent’s plea and discussions with prosecutors.
PSI and victim’s affidavit included the $19,866.69 as losses tied to Cadorette’s medical care after the offense.
Cadorette testified the suicide attempt was directly related to the assault and the prosecutor/defense discussion as to the case.
The district court sentenced eight years with three years suspended and restitution totaling $44,112.74, including the suicide-related medical expenses.
On appeal, Jent challenges only the inclusion of the $19,866.69 as restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether suicide-related medical costs are recoverable as restitution	Cadorette’s losses are “as a result of” the offense	Costs were not a result of the offense; self-inflicted	Yes, costs are recoverable as restitution
Whether a causal link exists between the aggravated assault and suicide-related expenses	The assault caused mental health decline leading to suicide attempt	No direct link; losses too attenuated	Yes, there is a causal connection between the offense and the medical expenses
Whether the district court’s nexus and evidentiary bases support restitution for the suicide-related costs	Affidavit and testimony establish nexus; mitigation not required	Insufficient proximate cause; defendant could contest at civil standard	Yes, substantial evidence supports nexus and amount of restitution

Campbell v. Young Motor Co., 211 Mont. 68 (Mont. 1984) (chain-of-causation doctrine for suicide and injury damages applied to restitution context)
Ness, 352 Mont. 317, 216 P.3d 773 (Mont. 2009) (restitution requires nexus to underlying offense; proximate cause considerations)
LaTray, 302 Mont. 11, 11 P.3d 116 (Mont. 2000) (restitution not limited to direct injuries; broader scope of recoverable losses)
Grindheim, 323 Mont. 519, 101 P.3d 267 (Mont. 2004) (restitution for future counseling costs related to offense)
Perkins, 350 Mont. 387, 208 P.3d 386 (Mont. 2009) (childcare/removal in restitution context due to offender’s acts)
Warclub, 327 Mont. 352, 114 P.3d 254 (Mont. 2005) (mixed question standard for restitution involving legal standards)
City of Billings v. Edward, 366 Mont. 107, 285 P.3d 523 (Mont. 2012) (causal connection and nexus in restitution framework)
Brownback, 356 Mont. 190, 232 P.3d 385 (Mont. 2010) (restitution scope for pecuniary losses arising from crime)