State of Minnesota v. Berry Alan Willis

OPINION

BJORKMAN, Judge.

Appellant challenges the restitution award in this aggravated forgery case, arguing that the district court erred by (1) considering hearsay evidence of the victim’s economic loss and (2) ordering restitution for expenses the victim incurred prior to appellant’s charged conduct. Because the rules of evidence do not apply to restitution hearings but restitution awards must reflect loss directly caused by the offense, we affirm in part, reverse in part, and remand.

FACTS

On October 28, 2013, appellant Berry Alan Willis filed a quitclaim deed in the name of P.H. to transfer…