State v. Rodriguez

Defendant appeals a judgment of conviction for harassment and a supplemental judgment requiring defendant to pay $2,893.20 in restitution to the victim for her out-of-pocket medical expenses and lost wages. ORS 137.106.1

In ordering restitution, the trial court had concluded that, based on then-current case law, a causal connection existed between defendant’s criminal conduct and the victim’s economic damages because that conduct was the “but-for” cause of the victim’s injury. After the entry of the restitution judgment, the Supreme Court decided State v. Ramos, 358 Or 581, 368 P3d 446 (2016).…