State v. Watson
2021 UT App 37
| Utah Ct. App. | 2021Background:
- Watson engaged in road-rage conduct: repeatedly brake-checked, swerved toward, rear-ended, threatened, and attempted to assault Victim; bystanders intervened and Watson displayed a pocketknife.
- Watson was tried and convicted of assault and reckless driving (misdemeanors) and an infraction; sentenced to probation and a suspended jail term.
- The district court ordered Watson to pay $1,980 in restitution to the Utah Office for Victims of Crime (UOVC) for 25 mental‑health therapy sessions UOVC had paid for Victim.
- At the restitution hearing the State offered only (1) an itemized UOVC payment list showing 25 “Mental Health Therapy” sessions and amounts and (2) testimony from a UOVC restitution specialist about UOVC’s ordinary review/authorization procedures; neither treatment plans, progress notes, therapist testimony, nor other direct evidence of crime‑causation for each session was introduced.
- The restitution specialist testified UOVC payments are authorized only if a claims analyst determines services are “crime related,” but conceded this review does not apply a proximate‑cause standard and that therapy could include topics unrelated to the crime.
- The district court found Watson’s conduct “absolutely caused” Victim’s need for therapy and ordered restitution; the Court of Appeals vacated that restitution order for failure to prove proximate cause.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether State met its burden to prove proximate cause for restitution for Victim’s therapy | UOVC’s approval and the restitution specialist’s testimony show the therapy was crime‑related and trial evidence shows Watson caused Victim’s trauma | UOVC payment records and general procedure testimony are insufficient to prove but‑for and foreseeable causation for each session; State needed direct evidence (e.g., therapist testimony, treatment plan, progress notes, or Victim’s testimony about symptoms) | Reversed — State failed to prove proximate cause; UOVC’s “crime‑related” administrative approval is a lower standard and does not substitute for court’s independent proximate‑cause determination |
| Whether the district court may rely on UOVC’s administrative findings in lieu of independent evidence | UOVC’s claims analysis establishes crime‑relatedness and supports restitution | Court may not delegate proximate‑cause determination to an administrative agency; district court must evaluate causation from the record before it | Reversed — district court cannot rely solely on UOVC determinations; it must have evidence in the record permitting an independent proximate‑cause finding |
Key Cases Cited
- State v. Ogden, 416 P.3d 1132 (Utah 2018) (clarified proximate‑cause standard and review for restitution awards)
- State v. Becker, 427 P.3d 306 (Utah Ct. App. 2018) (restitution requires proof that defendant’s conduct produced the injury and that injury would not have occurred absent the crime)
- State v. Morrison, 440 P.3d 942 (Utah Ct. App. 2019) (places burden on the State to prove proximate cause in restitution cases)
- State v. Brown, 221 P.3d 273 (Utah Ct. App. 2009) (court cannot delegate its independent restitution/cause determination to an administrative agency)