State v. McLane
McLane
Citation
341 Or. App. 289
Court
Court of Appeals of Oregon
Decided
June 11, 2025
Jurisdiction
SA
Importance
45%
Practice Areas
Case Summary
No. 535 June 11, 2025 289 This is a nonprecedential memorandum opinion pursuant to ORAP 10.30 and may not be cited except as provided in ORAP 10.30(1). IN THE COURT OF APPEALS OF THE STATE OF OREGON STATE OF OREGON, Plaintiff-Respondent, v. CHRISTINA MARIE McLANE, Defendant-Appellant. Lake County Circuit Court 22CR12877; A180657 David M. Vandenberg, Judge. Submitted September 25, 2024. Ernest G. Lannet, Chief Defender, Criminal Appellate Section, and Brett J. Allin, Deputy Public Defender, Office of Public Defense Services, filed the brief for appellant. Ellen F. Rosenblum, Attorney General, Benjamin Gutman, Solicitor General, and Greg Rios, Assistant Attorney General, filed the brief for respondent. Before Shorr, Presiding Judge, Powers, Judge, and Pagán, Judge. PAGÁN, J. Affirmed. 290 State v. McLane PAGÁN, J. Defendant was convicted of reckless burning pursu- ant to ORS 164.335. On appeal of the judgment of conviction, she raises one assignment of error, challenging the award of $6,900 in restitution. Defendant argues that the state failed to produce sufficient evidence that the replacement costs incurred were reasonable and that all of the damages were caused by defendant’s reckless burning. For the following reasons, we affirm. Defendant pleaded guilty to reckless burning, and, in her plea, admitted to starting a fire on the victim’s prop- erty that spread to, and eventually damaged, the victim’s manufactured trailer home that was on the property. The state sought $6,900 in restitution to compensate the vic- tim. At the restitution hearing, the victim testified that the damage done to her trailer was caused by the fire that was set by defendant, and that she and her husband did not have insurance to pay for the damage. She also testified that she repaired the trailer with her husband and provided an informal accounting which included trips to Home Depot for replacement appliances and parts. The state submitted photos of damage to the trailer (including pictures of dam- age to the interior and pictures of the repairs made), a com- parative real-estate market analysis estimating a value of $20,000 to $30,000 for the victim’s trailer, a tax assessment listing the trailer’s value as $2,290, and a list of items that the victims bought to repair the damages that defendant caused. Defendant objected to the requested restitution, arguing that the court should value the victim’s trailer at $2,290 and disregard the repair costs, stating that, under the economic damages statute, the victim was entitled to recover “reasonable costs incurred for repair, or replacement of damaged property, whichever is less.” Defendant further argued that the state had not presented “hard evidence” of the reasonableness of the costs. The trial court took the mat- ter under advisement and issued a letter opinion that con- cluded, “the Court finds restitution in the amount of $6,900 is owed to the victim in this matter.” Nonprecedential Memo Op: 341 Or App 289 (2025) 291 On appeal, defendant raises one assignment of error and supports the assignment with two arguments.1 First, defendant argues that there was insufficient evidence that the amounts incurred for repairs were reasonable. Second, defendant argues that the state failed to provide sufficient evidence that the damages sought were only for damages that were causally related to defendant’s conduct. We review a trial court’s imposition of restitution for legal error, accepting all factual findings to the extent that evidence in the record supports them. State v. Woods, 284 Or App 559, 565, 393 P3d 1188, rev den, 361 Or 801 (2017). Under ORS 137.106(2)(a), ORS 31.705 is applicable to restitution hearings. Regarding economic damages, ORS 31.705(2)(a) states: “ ‘Economic damages’ means objectively verifiable monetary losses including but not limited to reasonable charges nec- essarily incurred for medical, hospital, nursing and reha- bilitative services and other health care services, burial and memorial expenses, loss of income and past and future impairment of earning capacity, reasonable and necessary expenses incurred for substitute domestic services, recur- ring loss to an estate, damage to reputation that is econom- ically verifiable, reasonable and necessarily incurred costs due to loss of use of property and reasonable costs incurred for repair or for replacement of damaged property, which- ever is less.” We conclude that the trial court did not err in awarding the $6,900 because there was sufficient evidence for the court to conclude both that the costs we
Case Details
Case Details
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Status
Decided
Date Decided
June 11, 2025
Jurisdiction
SA
Court Type
federal
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Case Summary
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Case Overview
State v. McLane is a notable case decided by the Court of Appeals of Oregon on June 11, 2025. The case revolves around the conviction of Christina Marie McLane for reckless burning under ORS 164.335. Following her conviction, McLane appealed the restitution amount awarded to the victim, challenging both the reasonableness of the costs and the causal relationship between her actions and the damages incurred.
Key Legal Issues
The primary legal issues in this case include:
- Sufficiency of Evidence: Whether the state provided adequate evidence to support the restitution amount of $6,900.
- Causation: Whether the damages claimed were directly caused by McLane's reckless actions.
Court's Decision
The Court of Appeals affirmed the trial court's decision, upholding the restitution award of $6,900 to the victim. The court found sufficient evidence supporting both the reasonableness of the repair costs and the causal link between McLane's actions and the damages.
Legal Reasoning
In its analysis, the court emphasized the following points:
- Admission of Guilt: McLane pleaded guilty to reckless burning, acknowledging her role in starting the fire that damaged the victim's property.
- Victim Testimony: The victim provided credible testimony regarding the damages and the costs incurred for repairs, including an informal accounting of expenses and photographic evidence of the damage.
- Economic Damages Definition: Under ORS 31.705(2)(a), economic damages encompass reasonable costs incurred for repair or replacement of damaged property, which the court found applicable in this case.
Key Holdings
- The court found that the trial court did not err in awarding restitution based on the evidence presented.
- The victim's testimony and supporting documents sufficiently demonstrated that the costs incurred were reasonable and directly related to the damages caused by McLane's actions.
Precedents and Citations
- State v. Woods, 284 Or App 559 (2017) - Established guidelines for reviewing restitution awards.
- State v. Kirkland, 268 Or App 420 (2015) - Clarified the prerequisites for awarding restitution, including criminal activities, economic damages, and causation.
Practical Implications
This case underscores the importance of presenting comprehensive evidence in restitution hearings, particularly in cases involving property damage. Legal professionals should note the following implications:
- Evidence Requirements: The necessity for clear and credible evidence to support claims for restitution, including detailed accounts of expenses and damages.
- Causation in Restitution: The need to establish a direct causal link between the defendant's actions and the damages claimed, which is crucial for the successful recovery of restitution amounts.
- Judicial Discretion: The court's discretion in determining the reasonableness of costs and the sufficiency of evidence presented by both parties.
In conclusion, State v. McLane serves as a significant case in the realm of restitution law in Oregon, highlighting the standards for evidence and the court's approach to determining reasonable costs associated with property damage due to criminal conduct.
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Case Details
Legal case information
Status
Decided
Date Decided
June 11, 2025
Jurisdiction
SA
Court Type
federal
Legal Significance
Case importance metrics
Metadata
Additional information
Quick Actions
Case management tools