State v. Bullock, 899 P.2d 709 (Or. Ct. App. 1995)

Cases | State v. Bullock, 899 P.2d 709 (Or. Ct. App. 1995) | 2018

The defendant was convicted of four counts of sodomy in the first degree, three counts of rape in the first degree, four counts of sexual abuse in the second degree, unlawful sexual penetration in the first degree, and two counts of unlawful sexual penetration in the second degree. As part of the sentence, the defendant was ordered to pay restitution to Children’s Services Division (CSD) for treatment and care and to Adult and Family Services (AFS) for medical expenses. On appeal, the defendant claimed that the orders of restitution to CSD and AFS were in error because the state did not show a causal relationship between his criminal activity and the pecuniary harm suffered by the two entities, claiming that the victim’s own free will and self-determination intervened. The appeals court found that the victim’s behavioral and emotional problems, treated by the CSD and AFS, were natural consequences of the defendant’s sexual abuse and affirmed the order of restitution.