Martinez v. People
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In the case before the Supreme Court of the State of Colorado, Arnold Roman Martinez stole a bicycle from the garage of C.T. Pursuing Martinez in his car, C.T. pulled in front of Martinez, leading to a collision that damaged C.T.’s vehicle. Martinez was subsequently ordered to pay restitution for the damage to the car as part of a plea agreement in a criminal case. Martinez contested the restitution order, arguing that he did not proximately cause the car damage.
The Supreme Court held that the appropriate standard of review for evaluating a district court’s determination of proximate cause for restitution is clear error, not abuse of discretion as had been applied by the lower courts. The court reasoned that the proximate cause inquiry is primarily a fact-based determination, and that trial courts are better situated to resolve such disputes. It also noted that the statutory language and structure suggest that the standard of review should allow for expedient resolution of restitution decisions.
Applying this standard, the Supreme Court found no clear error in the district court’s determination that Martinez had proximately caused the car damage. The court determined that C.T.’s actions were foreseeable and not grossly negligent, and that Martinez had participated in the events leading to the collision. Therefore, the Supreme Court affirmed the lower court's decision that Martinez was obligated to pay restitution.
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