State v. Joyce, 681 N.W.2d 468 (S.D. 2004)

Cases | State v. Joyce, 681 N.W.2d 468 (S.D. 2004) | 2018

The defendant struck the victim’s car and fled the scene. The defendant pled guilty to failure to provide information and was ordered to pay restitution for the victim’s medical and vehicle damages, among other expenses. The defendant appealed the restitution order on the basis that the victim’s damages were caused by the accident, rather than his leaving the scene of the accident. The court reversed the portion of the judgment ordering restitution for the victims’ medical and vehicle damages. South Dakota’s restitution statutes require a causal connection between a defendant’s crime and a victim’s damages. The defendant’s act of leaving the scene did not cause the victim’s injuries and resulting damages.