Legal Opinion

State v. Harris

Court of Appeals of Washington

Decided June 23, 2014No. 69729-3-IPublishedCited by 5 opinions

1Opinion of the CourtBecker, J.

¶1 Statutory restitution may be ordered under RCW 9A.20.030(1) if the State proves that the crime was a “but for” cause of the victim’s loss. Washington does not require proof of proximate cause as that term is used in tort law. In this case, the loss was burial expenses for a woman who died after appellant John Harris ran into her with his car. Harris was driving with a suspended license at the time and was convicted of that crime. Harris should not have been driving, and if he had not been driving, he would not have hit the pedestrian. We conclude driving with a suspended license was a “but…

2Cases cited18 opinions

  1. State v. KrallWashington Supreme Court · 1994
  2. Daniels v. WoodfordCourt of Appeals for the Ninth Circuit · 2005
  3. State v. IrbyWashington Supreme Court · 2011
  4. In Re Personal Restraint of StensonWashington Supreme Court · 2001
  5. In re the Personal Restraint of StensonWashington Supreme Court · 2001

13 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. Brianna Marie Peterson v. Municipality of AnchorageCourt of Appeals of Alaska · 2021
  2. State Of Washington v. John B. VelezmoroCourt of Appeals of Washington · 2016
  3. STATE OF FLORIDA v. ANTHONY LEVERN WAITERSDistrict Court of Appeal of Florida · 2022
  4. State Of Washington, Res. v. Juan Cruz-grijalva, App.Court of Appeals of Washington · 2015
  5. State of Washington v. Thomas Gerald MarlinCourt of Appeals of Washington · 2019

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