State v. Pierre
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The Supreme Court reversed Defendant's conviction and sentence for burglary, holding that the district court erred by requiring Defendant to pay restitution for pecuniary losses resulting from offenses committed by others absent evidence of criminal accountability or a causal connection between Defendant's offense and those losses.
Defendant was one of several persons involved in multiple burglaries of the main house, garage, and separate guest house owned by Elden and Betty White. Defendant pled guilty to burgling the guest house. The district court concluded that Defendant should be jointly and severally responsible with his associates for the entire amount of pecuniary loss of $43,294 sustained by the Whites as a result of the burglaries. The Supreme Court reversed the restitution order, holding that where there was no record evidence that Defendant's admitted commission of the guest house burglary directly caused any pecuniary loss resulting from any burglary of the main house or garage by others, the district court erred by ordering Defendant to pay restitution for pecuniary losses sustained by the Whites as a result of the burglaries of their main house.
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