State v. Jonathan M. Battle

Battle was convicted on Count III domestic violence with traumatic injury based on grabbing and pushing the victim, causing bruising and abrasions.
The district court ordered Battle to pay $1,803.96 in restitution to the Victims Compensation Program for the victim’s CT angiogram.
The angiogram was performed to assess vascular damage after the victim reported neck grabbing and injuries.
Evidence included the victim’s testimony, nurse/doctor observations of injuries, and a bruise photo of the neck.
The restitution decision followed I.C. § 19-5304 and related case law, applying a discretionary review for reasonable, causally linked economic losses.
Appellant argues the angiogram costs were not causally connected to Count III’s conduct; the State contends the neck grabbing causally caused the injury and resulting medical test.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the CT angiogram cost is a recoverable restitution amount.	Battle argues no causal link to Count III.	Bybee/Richmond framework requires causation to the crime.	Yes; causally related to the crime and upheld.

State v. Richmond, 137 Idaho 35, 43 P.3d 794 (Ct. App. 2002) (restitution requires full-compensation and discretionary review standards)
State v. Bybee, 115 Idaho 541, 768 P.2d 804 (Ct. App. 1989) (guides restitution discretion and purpose)
State v. Lombard, 149 Idaho 819, 242 P.3d 189 (Ct. App. 2010) (causation and preponderance standard for economic loss)
State v. Corbus, 150 Idaho 599, 249 P.3d 398 (Ct. App. 2011) (defines causation elements for restitution; actual and proximate cause)
State v. Hill, 154 Idaho 206, 296 P.3d 412 (Ct. App. 2012) (restoration of economic loss; causation scope)
State v. Lampien, 148 Idaho 367, 223 P.3d 750 (Ct. App. 2009) (causation and limits on restitution to linked crimes)
State v. McKeeth, 136 Idaho 619, 38 P.3d 1275 (Ct. App. 2001) (restitution must be limited to crimes convicted of)