State v. BoettcherAnnotate this Case
The Supreme Court reversed the judgment of the court of appeals affirming the decision of the district court ordering Defendant to pay restitution for destruction of a cabin after a jury found him guilty of burglary but did not reach a verdict on an arson charge, holding that the court of appeals erred by applying an incorrect standard.
Defendant was charged with second-degree burglary and first-degree arson for the destruction of a cabin in Minnesota that was burglarized and then set on fire. The jury found Defendant guilty of burglary but could not reach a verdict on the arson charge. The State declined to retry Defendant for arson, but, after determining that the arson was factually related to the burglary, ordered Defendant to pay restitution for the fire-damaged cabin. The court of appeals affirmed, concluding that the burglary and the fire were sufficiently "factually intertwined" to allow restitution. The Supreme Court reversed, holding that the court of appeals erred by applying a factual-relationship standard rather than a direct-causation standard when considering whether fire damage to the cabin was a result of Defendant's offense.