Cited by
Opinions in Minnesota that cite State v. Boettcher, 931 N.W.2d 376.
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A25-1156
Minn. Ct. App. 2026
Before awarding restitution, “the district court must consider the defendant’s ability to pay and the loss sustained by the victim of the crime.”
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Paul Scott Seeman, petitioner, Appellant,
Minn. Ct. App. 2025
District courts “may order restitution only for losses that are directly caused by, or follow naturally as a consequence of, the defendant ’s crime.” State v. Boettcher
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Unless the record shows that the defendant agreed to pay for losses as part of a plea agreement, “a district court may order restitution only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.” n.5 (Minn. 2019); –78 (Minn. App. 1996) (affirming a district court’s order denying a defendant’s motion to vacate restitution to the “buy fund” of a police drug task force, which was imposed pursuant to a plea agreement), rev. denied (Minn. May 21, 199
- Karl Alfredo Rosillo, petitioner, Appellant, vs. State of Minnesota, Respondent Minn. Ct. App. 2025
- Karl Alfredo Rosillo, petitioner, Appellant, vs. State of Minnesota, Respondent Minn. Ct. App. 2025
- State of Minnesota, Respondent, vs. Paul Scott Seeman, Appellant Minn. 2025
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State of Minnesota, Respondent, vs. Paul Scott Seeman, Appellant
Minn. 2025
“A [district] court abuses its discretion when its decision is based on an erroneous view of the law.” State v. 6 Boettcher, (citation omitted) (internal quotation marks omitted).
- In the Matter of the Welfare of: S. A. A., Child. Minn. Ct. App. 2025
- In the Matter of the Eligibility of R.M.C. for Crime Victim Reimbursement - Reimbursement Claim No. 048733. Minn. Ct. App. 2025
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
District courts “may order restitution only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
The district court may order restitution 4 only for injuries that are “directly caused by, or follow naturally as a consequence of, the defendant’s crime,” and this excludes funds or items allegedly stolen before the period during which the defendant’s crimes of conviction occurred.
- State of Minnesota, Respondent, Minn. Ct. App. 2025
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Restitution is proper so long as it is not “so attenuated in its cause that it cannot be said to result from the defendant’s criminal act.” (explaining that “a district court may order restitution only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime” (footnote omitted)).
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A24-1098
Minn. Ct. App. 2025
“A [district] court abuses its discretion when its decision is based on an erroneous view of the law.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Restitution may be ordered for a victim’s losses only if the losses “are directly caused by, or follow naturally as a consequence of, the defendant’s crime.”
- State of Minnesota, Respondent, Minn. Ct. App. 2024
- State of Minnesota v. Reymundo Gonzalez Minn. Ct. App. 2024
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State of Minnesota v. Reymundo Gonzalez
Minn. Ct. App. 2024
But restitution may be ordered “only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.”
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State of Minnesota, Appellant,
Minn. Ct. App. 2024
The district court “may order restitution only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.” -67 (Minn. 2007) (declining to adopt the more expansive but-for test for causation).
- In the Matter of the Welfare of: S. S. M., Child. Minn. Ct. App. 2024
- State of Minnesota v. Paul Scott Seeman Minn. Ct. App. 2024
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State of Minnesota v. Paul Scott Seeman
Minn. Ct. App. 2024
The district court “may order restitution only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.”
- State of Minnesota v. Steven Craig Morrow Minn. Ct. App. 2024
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State of Minnesota v. Steven Craig Morrow
Minn. Ct. App. 2024
But restitution may be ordered only “for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
Restitution may be ordered only “for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.”
- State of Minnesota v. Henry Albert Allison, Jr. Minn. 2024
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State of Minnesota v. Henry Albert Allison, Jr.
Minn. 2024
n.5 (Minn. 2019), we emphasize that our analysis here does not alter the Kennedy rule that allows a court to order restitution for losses incurred as a direct result of dismissed charges when the defendant agrees to pay restitution in connection with those charges as part of the parties’ plea negotiation.
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
-81 (Minn. 2019) (rejecting the state’s 6 argument that a “but-for” test should apply in restitution matters and clarifying the rule as permitting restitution “only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime”).
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
is that a district court may order restitution only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
It is also true that the loss must be “directly caused by, or follow naturally as a consequence of, the defendant’s crime.”
- A22-1051 Minn. Ct. App. 2023
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
The district court “may order restitution only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.”
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Minn. 2022
6 The dissent also cites State v. Boettcher , (addressing restitution after jury trial).
- State of Minnesota, Respondent, Minn. Ct. App. 2022
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Minn. 2022
We have also addressed the proper causal scope of a restitution award, holding that the term “result” as used in this factor, permits district courts to consider only losses “that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.” d 376, 380–81 (Minn. 2019).
- A21-0480 Minn. Ct. App. 2022
- State of Minnesota, Respondent, Minn. Ct. App. 2022
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
“[District courts] may order restitution only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.” State v. Boettcher
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State of Minnesota,
Minn. 2021
’s income, resources, and obligations when ordering restitution, and that the record must include sufficient evidence about the defendant’s income, resources, and obligations to allow a district court to consider the defendant’s ability to pay 1 We have referred to “the income, resources, and obligations of the defendant” as the defendant’s “ability to pay.” See
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
“A [district] court abuses its discretion when its decision is based on an erroneous view of the law.” (quotation omitted).
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Emily Anna Jones, petitioner, Appellant,
Minn. Ct. App. 2021
“To determine whether to order restitution and the amount of restitution, a district court must consider the defendant’s ability to pay and the loss sustained by the victim of the crime.” (emphasis added) (quotation omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2021
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
A distric t court has broad discretion in awarding restitution, id., but it abuses its discretion “when its decision [regarding restitution] is based on an erroneous view of the law.” 380 (Minn. 2019).
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
But a district court “may order restitution only for losses that are directly caused by, or follow naturally as a consequence of, the defendant’s crime.” (emphasis added).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
“The district court has broad discretion to award restitu tion, and the district court’ s order will not be reversed absent an abuse of that discretion.” (quotation omitted).
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In the Matter of the Welfare of:
Minn. Ct. App. 2020
And the supreme court has clearly articulated that “a district court may order restitu tion only for losses that are di rectly caused by, or follow naturally as a consequence of, the defendant’s crime.”