State v. Mooers, 424 P.3d 1126

In Nov. 2012 the Mooerses’ house was burglarized: a basement bedroom window was broken, carpet damaged, and about $3,200 in jewelry/coins stolen; some items were later recovered at a pawn shop.
Ryan Mooers admitted aiding others in the break-in; he pled in abeyance to theft (third-degree) while burglary was dropped; plea included an 18‑month abeyance and restitution.
The State sought $5,760.50 in restitution: stolen property, window repair, carpet replacement, and $1,100 to install security bars on the bedroom window.
The district court ordered full restitution, including the security‑bar cost, finding the bars were installed because of the break‑in and were not temporally or factually attenuated.
On appeal the court considered whether post‑burglary security bars qualify as "pecuniary damages" under Utah Code § 77‑38a‑102(6); the court vacated the security‑bar portion and remanded for an amended order covering only stolen/damaged property.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether cost to install security bars after a burglary is "pecuniary damages" compensable as restitution	State: bars were an economic, objectively verifiable expense causally linked to the crime and would not have been needed but for the burglary	Mooers: bars are a voluntary security improvement, not a loss or harm to property and thus not pecuniary damages under the statute	Court: security bars are not pecuniary damages because they were not "taken, destroyed, broken, or otherwise harmed" and no demonstrable economic injury existed prior to installation; restitution for bars vacated
Whether defendant’s plea to theft (not burglary) precludes restitution for security measures prompted by the burglary	State: Mooers admitted involvement in break‑in and agreed to pay restitution including for dismissed charges as part of plea	Mooers: having pled only to theft, he is not responsible for burglary‑related measures	Court: moot on the merits because security bars are not compensable; but factual admissions and plea terms would have made liability plausible if bars qualified as pecuniary damages

State v. Brown, 342 P.3d 239 (Utah 2014) (statutory definition of pecuniary damages includes fair‑market value of property taken or harmed and excludes pain and suffering)
State v. Corbitt, 82 P.3d 211 (Utah Ct. App. 2003) (appellate review standard: disturb restitution order only for abuse of discretion or if it exceeds statutory authority)
State v. Rackham, 381 P.3d 1161 (Utah Ct. App. 2016) (statutory citations and amendment note used in restitution analysis)