Martinez v. People. [original decision published February 5, 2024]

2024 CO 6M. No. 22S272. Criminal Law—Restitution—Standard of Review—Proximate Cause.

March 25, 2024

In this case, the Supreme Court held that clear error is the standard for reviewing a district court’s determination of proximate cause for criminal restitution. In so doing, the Court rejected the division majority’s reliance on the abuse-of-discretion standard. The Court further concluded that the district court did not clearly err in determining that Martinez was the proximate cause of the victim’s pecuniary loss. Accordingly, the Court affirmed the division’s judgment on other grounds.