State v. Taylor

This appeal concerns a restitution order in a case of welfare fraud. We reverse for lack of a causal connection between the crime of conviction—second degree theft—and the damages awarded.

Welfare fraud is a form of theft, the degree of which depends on the monetary amount involved. Welfare fraud in the first degree is theft of a sum greater than $1,500. The State alleged Moses Taylor fraudulently received $9,074 in welfare benefits. A jury convicted him of the lesser included offense of second degree theft, which is theft of an amount between $250 and $1,500. The trial court nevertheless…