State v. AlcalaAnnotate this Case
Defendant pleaded guilty to first-degree premeditated murder for killing his estranged wife. The district court sentenced Defendant to life imprisonment without parole for twenty-five years, ordered Defendant not to have any contact with the victim’s family, and imposed a restitution order requiring Defendant to pay attorney fees incurred by the victim’s mother in child in need of care (CINC) proceedings involving the couple’s children and a separate legal action finalizing her adoption of the children. Defendant appealed his sentence. The Supreme Court vacated the no-contact order and affirmed the restitution order, holding (1) in line with caselaw, the no-contact order should be vacated because it constituted an illegal sentence where it is a probation condition that cannot be imposed in conjunction with prison sentences; and (2) a sufficient causal link existed between Defendant’s unlawful conduct and the attorney fees for the CINC proceedings and adoption case, and the district court properly rejected the claim that any restitution plan was unworkable.