State v. Ruiz, 305 P.3d 223

Ruiz, convicted of two counts of attempted unlawful sexual activity with a minor, faces restitution liability after a nine-month inpatient Victim therapy expenditure totaling $51,995.
Victim underwent extensive inpatient treatment at La Europa due to Ruiz's actions, with prior preexisting mental health issues and family problems contributing to treatment needs.
Trial court found Victim's treatment costs reasonable and tied to Ruiz's conduct, ordering full restitution in installments.
Court acknowledged Victim's preexisting conditions but required causal nexus showing Ruiz's actions caused the specific losses.
Ruiz argued the complete restitution calculation should account for preexisting conditions and attenuated causal connection; court also considered installment payments under Utah law.
On appeal, the Utah Court of Appeals reverses the complete restitution calculation but affirms the exercise of discretion on court-ordered restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether complete restitution properly accounts for Victim’s preexisting conditions	Ruiz contends preexisting issues attenuate causal link	State argues full causation by Ruiz's conduct and near total linkage	Remand for detailed findings on preexisting-condition impact
Whether the court erred in imposing full court-ordered restitution despite Ruiz’s ability to pay	Ruiz asserts installment plan insufficiently considers resources	State argues court properly weighed resources and rehabilitative effects	Remand may adjust installment plan within statutory factors
Whether the trial court properly linked Victim’s costs to Ruiz’s crime under the modified but-for test	Ruiz says costs beyond direct losses were too attenuated	State maintains costs were connected to the crime via therapy necessitated by the assault	Remand for clarified causal nexus and allocation of costs to Ruiz

State v. Harvell, 220 P.3d 174 (Utah Court of Appeals 2009) (modified but-for test for complete restitution; causal nexus requirements)
State v. Mast, 40 P.3d 1143 (Utah Court of Appeals 2001) (restitution when defendant admits to only part of conduct; liability tied to culpable acts)
State v. Laycock, 214 P.3d 104 (Utah Supreme Court 2009) (discretion to award or deny restitution and record explanation required)
State v. Brown, 221 P.3d 273 (Utah Court of Appeals 2009) (relocation-like expenses may be too attenuated to include in complete restitution)
Behnke v. Wisconsin, 553 N.W.2d 265 (Wis. App. 1996) (restitution for emotional injuries when precipitated by defendant's actions; preexisting conditions Burn not bar full recovery)