State v. Thomas, 372 P.3d 87

Thomas pled guilty to third-degree burglary and criminal mischief for damaging a newly constructed house with a hatchet; total agreed "complete restitution" was $10,629.
Thomas requested a hearing on his ability to pay court-ordered restitution; he submitted a financial declaration and testified about limited, recent employment (~$1,000/month gross), modest expenses, and living with his father.
District court considered Thomas’s income, expenses, mental health, education, and employment prospects, but based the restitution determination on current income.
The court imposed court-ordered restitution of $10,629, payable at $125/month with 3% interest, and extended court probation to eight years to facilitate payment.
Defense argued the court failed to reasonably consider Thomas’s limited resources and that $125/month was an undue burden; the State argued the record shows the court considered his finances.
The appellate court reviewed for abuse of discretion and affirmed the district court’s restitution order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court abused its discretion in setting court-ordered restitution equal to complete restitution	Thomas: court did not reasonably consider his limited financial resources or the burden of $125/month; identical amounts show required factors were ignored	State: record demonstrates the court was aware of and considered Thomas’s financial situation and other factors	Affirmed — no abuse of discretion; identical amounts do not alone show failure to consider statutory factors

State v. Laycock, 214 P.3d 104 (Utah 2009) (court-ordered restitution may equal or differ from complete restitution depending on statutory factor analysis)
State v. Corbitt, 82 P.3d 211 (Utah Ct. App. 2003) (appellate review of restitution is for abuse of discretion; overturn only if no reasonable person would take the trial court’s view)