State v. Parsons, 287 Or. App. 351

Defendant pleaded guilty to attempting to elude a police officer (ORS 811.540) and second‑degree criminal mischief (ORS 164.354) based on an incident at an Abercrombie & Fitch (A&F) store on February 4, 2015.
Store employee testified defendant took five pairs of pants into a dressing room, returned three (two shredded, one intact) and two pairs were missing; earlier in January nine pairs had been similarly shredded. Store claimed $1,074 total loss (including nine January items).
Officer Johnson pursued defendant after being given the license plate; he used lights/siren and, after a brief stop and continued flight through intersections, executed a PIT maneuver 43 seconds after initiating pursuit, damaging the patrol car.
City’s insurer (CCIS) paid $2,546.89 for repairs and the city paid a $500 deductible; officer testified repairs totaled $3,046.89.
Trial court ordered $4,120.89 restitution to A&F, the City of Tigard, and CCIS without explanation; defendant appealed, conceding $156 for the two shredded pairs but challenging other components.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Restitution for two missing pairs of pants	Missing pants are part of same facts/events as admitted intentional damage; restitution for full store loss is proper	Defendant was convicted of intentional damage, not theft, and did not admit stealing or hiding the missing pants	Vacated restitution for missing pants — no admissible conviction or admission tying defendant’s criminal activity causally to disappearance; state failed to show required causal nexus under ORS 137.106
Restitution for damage to patrol car (city deductible/insurer)	Patrol car damage flowed from defendant’s attempt to elude police; restitution appropriate	Officer’s PIT maneuver, performed as pursuit intervention, may have been premature; the patrol car damage may not have been a reasonably foreseeable result of defendant’s offense	Supplemental judgment vacated and remanded for trial court to make an express factual finding whether the patrol car damage was a "reasonably foreseeable" result of defendant’s criminal activity (per State v. Ramos)
Restitution to insurer and January damages (preservation)	CCIS and January damaged pants are victims/damages presented at hearing	Defendant argues insurer is not a "victim" and he didn’t admit January damage; these issues were not preserved for appeal	Court declined to review unpreserved claims for plain error and did not reach those challenges

State v. Ramos, 358 Or. 581 (establishes that restitution requires damages to be a reasonably foreseeable result of defendant's criminal activity)
State v. Kirkland, 268 Or. App. 420 (standard for viewing evidence supporting restitution in light most favorable to the state)
State v. Stephens, 183 Or. App. 392 (restitution allowed where defendant's criminal acts facilitated later loss — ‘‘but for’’ causal connection)
State v. Doty, 60 Or. App. 297 (restitution upheld where defendant's admitted conduct created access that caused broader loss)