State v. A. E. A.

ORS 419C.450(1)(a) requires the juvenile court to award restitution for “injury, loss or damage” caused by the adjudicated youth and suffered by the victim. The juvenile court must award restitution when there is sufficient evidence of criminal activity, economic damages, and a causal relationship between the criminal activity and the economic damages. State v. C. A. M.-D., 312 Or App 4.

 Defendant juvenile appealed a “Judgement on Restitution and Money Awarded” entered against him. He argued that the trial court erred in ordering him to pay restitution for the damaged car he stole from his parents with his juvenile co-offender because he did not personally damage the car. ORS 419C.450(1)(a) requires the juvenile court to award restitution for “injury, loss or damage” caused by the adjudicated youth and suffered by the victim. The juvenile court must award restitution when there is sufficient evidence of criminal activity, economic damages, and a causal relationship between the criminal activity and the economic damages. State v. C. A. M.-D., 312 Or App 4. The Court found that the trial court properly ordered defendant to pay restitution on a joint and several basis with his codefendant to his parents' insurer. The Court reasoned that there was a reasonable inference that the vehicle would not have been damaged if defendant had not stolen it, even if direct control was exerted over the vehicle by the codefendant driving the vehicle.