State v. Grubb
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Brennan Grubb was convicted of sexually abusing a minor, which resulted in severe emotional trauma for the young boy. The boy's mother, a teacher, resigned from her job to care for her son. Grubb pleaded guilty to the charges and was ordered by the superior court to pay restitution, including compensation for the mother's future lost wages and benefits. Grubb appealed the restitution order, arguing that his criminal conduct was not the proximate cause of the mother's future lost wages and benefits. The court of appeals agreed with Grubb and vacated the restitution order.
The Supreme Court of the State of Alaska reversed the decision of the court of appeals. The court held that the mother's resignation from her teaching position was a reasonably foreseeable consequence of Grubb's criminal conduct. The court remanded the case to the court of appeals for further proceedings consistent with its opinion. The court emphasized that the legislature has steadily expanded the rights of crime victims to obtain restitution and that the statutory right to restitution must factor into the proximate cause analysis. The court also noted that the statutory definition of "victim" necessarily affects the proximate cause analysis. The court concluded that it was error to hold as a matter of law that Grubb's conduct could not be the proximate cause of the mother's future lost wages and benefits.
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