The Appellate Group

State v. Blake

State v. Blake, 2022 UT App 104 (Pohlman, J.)


Blake contests the district court’s restitution order for generic medical bills because there was insufficient evidence show that his criminal actions proximately caused the bills. The Utah Court of Appeals agreed and reversed, noting:

  • Insufficient evidence supported a determination that Blake’s criminal conduct proximately caused the medical services generically identified in the bills identified as a basis for the restitution order. Here, without reliance on UOVC’s conclusory determinations, the only evidence supporting the causal connection was that some unidentified medical charges occurred very close in time to the crime. This is not sufficient to establish proximate cause.

Read the full court opinion