State v. Walker, 936 N.W.2d 45

On July 10, 2018 Bismarck police stopped Chad Demonn Walker on a 2013 Honda motorcycle that lacked a license plate and matched a report of a stolen bike from Minot.
Officer Marquis confirmed the VIN showed the motorcycle was stolen and arrested Walker.
Walker pled guilty to possession of a stolen motorcycle (theft/possession charge).
The motorcycle owner submitted a victim impact statement and a commercial repair estimate of $2,410.69; the district court entered an amended judgment ordering Walker to pay that restitution amount.
Walker appealed, arguing (1) he was not accused of stealing or damaging the motorcycle and (2) the repair costs were not directly related to his criminal conduct; no transcript of the restitution hearing was provided on appeal.

Issue	State's Argument	Walker's Argument	Held
Whether restitution for repair costs must be directly related to the offense	Guilt for theft may be inferred from unexplained possession; damage occurred while the bike was in the defendant's possession, so a causal connection exists	Walker was charged only with possession, not with stealing or damaging the bike; repair costs are not necessarily a direct result of his offense	Restitution upheld: bike was returned damaged and the record contained a repair estimate; causal connection could reasonably be inferred
Whether the amount (estimate) was sufficient to support restitution	The commercial estimate in the record proved the amount by a preponderance	The estimate-based restitution should be reversed or remanded for a determination of unrelated expenses	Amount affirmed: the estimate was in the record and supported the award
Whether appellate review is barred by absence of a hearing transcript	N/A (relied on existing record)	Appellant contends he was denied opportunity to contest damage causation at trial; asks for reversal/remand	Court noted appellant failed to provide the restitution-hearing transcript; without it meaningful appellate review is impossible, so claim cannot prevail

State v. Rogers, 919 N.W.2d 193 (discusses standard of review for restitution and framework under N.D.C.C. § 12.1-32-08)
State v. Putney, 881 N.W.2d 663 (district courts have broad discretion in restitution awards)
State v. Pippin, 496 N.W.2d 50 (restitution limited to losses directly related to the defendant’s offense; reversal where record lacked causal connection)
State v. Carson, 900 N.W.2d 41 (cannot award restitution for damages caused by crimes for which defendant was not convicted)
State v. Kleppe, 800 N.W.2d 311 (State bears burden to prove restitution amount by a preponderance)
Chase v. State, 913 N.W.2d 774 (appellant must provide hearing transcript for meaningful appellate review)