State v. Venable

“When determining causation, a trial court must determine whether there is a ‘but-for’ connection between the victim’s damages and the crime and whether the victim’s economic damages were a reasonably foreseeable result of the defendant’s crime.” State v. Andrews, 366 Or 65, 69, 456 P3d 261 (2020).

Defendant appealed a supplemental judgment which ordered him to pay restitution to his victim. Defendant assigned error to the trial court’s imposition of economic damages that resulted from "Lyft fees." Defendant also assigned error to the trial court's causation requirement. “When determining causation, a trial court must determine whether there is a ‘but-for’ connection between the victim’s damages and the crime and whether the victim’s economic damages were a reasonably foreseeable result of the defendant’s crime.” State v. Andrews, 366 Or 65, 69, 456 P3d 261 (2020). Because the fees incurred in the days following the crime were within the spectrum of damages, the Court concluded that the trial court’s order was not erroneous. Affirmed.