State v. Hall
Annotate this CaseDefendant, who was employed at an animal clinic, altered computer records to erase outstanding bills for services performed for her own pets and stole clinic inventory. After a jury trial, Defendant was convicted of computer crime and left. The trial court imposed restitution in the amount of $14,293. A portion of this amount was based on the retail rather than the wholesale price of the stolen inventory. The court of appeals vacated the restitution order, holding, as a matter of law, that retail value was not a proper measure of restitution because the loss the clinic suffered was the wholesale price it had paid for the inventory. The Supreme Court affirmed but for other reasons, holding (1) in determining restitution for stolen inventory, there is no bright-line rule favoring either retail or wholesale cost; (2) rather, the sentencing judge must consider all the evidence to determine a value that compensates the victim for the actual loss caused by a defendant's crime; and (3) in this case, the sentencing judge's adoption of retail value as an appropriate measure of loss to the clinic for Defendant's theft of inventory was arbitrary and without substantial evidentiary support.
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