State of Iowa v. Terran E. Roache

WATERMAN, Justice.

In this appeal, we review the level of scrutiny for a criminal restitution award. The operator of a training course for commercial truck drivers imposed a $1900 "fine" on its student for the loss of a paperback study guide, a multiple of the full cost of the course that included the guide. The study guide was in a backpack stolen from the student's parked car. The student has not paid the fine, and his automobile insurer determined the paperback guide had no value. The district court presumed that $1900 far exceeded the actual cost to print the guide but nevertheless ordered…