State v. Lloyd Hardin McNeil, 158 Idaho 280

Lloyd McNeil was convicted of voluntary manslaughter, first‑degree arson, and grand theft after a fire that killed Natalie Davis; the convictions and sentence were affirmed on direct appeal.
After judgment, the State sought restitution totaling about $28,692.22, including counseling costs for the victim’s father and an airline ticket the father paid for the victim’s brother to attend the funeral.
McNeil timely objected to restitution and raised inability to pay; procedural confusion led to an initial restitution order, then two hearings to address objections.
The State presented no documentary or testimonial evidence establishing that the father’s post‑death counseling was caused by the crime, and offered only speculation that the topic was discussed in later sessions.
The State likewise presented no evidence that the brother’s flight was necessary to escort remains; it argued (without evidence or authority) that the brother accompanied the remains and therefore the ticket was a crime‑related expense.
The district court awarded most of the counseling and the airline ticket; the Court of Appeals vacated the restitution order and remanded, holding the State failed to prove causation for counseling and that travel to a funeral is too indirect to be compensable restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counseling costs for victim’s father are compensable restitution	Counseling sessions after the death were related to the crime and thus an economic loss caused by defendant	Father had begun counseling before the murder; State produced no evidence tying post‑death counseling specifically to the crime	Reversed: State failed to prove causation by a preponderance; speculative argument is insufficient
Whether airfare to attend victim’s funeral is compensable restitution	Ticket was necessary to escort remains (and/or to attend funeral) and thus an economic loss caused by defendant	Travel to a funeral is voluntary/indirect; Crime Victims Compensation Act excludes family travel; statute should be construed in defendant’s favor	Reversed: Travel to attend a funeral is too indirect a consequence to be recoverable as restitution

State v. Straub, 153 Idaho 882 (disallowed indirect economic losses such as increased insurance premiums after a death)
State v. Corbus, 150 Idaho 599 (restitution requires causal nexus between criminal conduct and claimed losses)
State v. Lampien, 148 Idaho 367 (explains actual and proximate cause standards in similar contexts)
State v. Hill, 154 Idaho 206 (restitution burden and standard of proof)
State v. Payne, 146 Idaho 548 (interpretation of "immediate family" in victim‑related statutes)