People v. Crigler, 625 N.W.2d 424 (Mich. Ct. App. 2001)

Cases | People v. Crigler, 625 N.W.2d 424 (Mich. Ct. App. 2001) | 2018

The defendant pled guilty to three counts of delivery of marijuana and was ordered to pay $7650 in restitution to the Michigan State Police Narcotics Enforcement Team (NET) for buy money expended to purchase marijuana during the course of his criminal transactions. The defendant appealed. The appellate court held that from the plain language of Mich. Comp. Laws Ann. § 780.766, as well as from the intent behind the Crime Victim’s Rights Act, the Legislature intended to permit narcotics enforcement teams to obtain restitution of buy money lost to a the defendant as a result of the defendant’s criminal act of selling controlled substances. The court’s decision in People v. Chupp, 200 Mich. App. 45, 503 N.W.2d 698 (Mich. Ct. App. 1993) was not controlling because at the time it was decided § 780.766 did not specifically provide that a governmental entity could be a victim. The NET was “injured or damaged” within the commonly used meaning of the word “harm” to the extent that it lost $7650 and its ability to conduct further narcotics investigations was curtailed because of the loss.