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Sufficiency of Evidence – Restitution

By: Derek Hawkins//April 25, 2018//

Sufficiency of Evidence – Restitution

By: Derek Hawkins//April 25, 2018//

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WI Court of Appeals – District IV

Case Name: State of Wisconsin v. Angela C. Nellen

Case No.: 2017AP257-CR

Officials: BLANCHARD, J.

Focus: Sufficiency of Evidence – Restitution

Angela Nellen appeals two elements of the circuit court’s order of restitution following Nellen’s conviction on two counts of theft of movable property. First, Nellen argues that the court erroneously exercised its discretion in ordering $90,000 in restitution to the owners of a coin collection that Nellen stole, because there was insufficient evidence presented at the restitution hearing to support a finding that the coin collection had this value. Second, Nellen argues that the circuit court lacked statutory authority to order restitution for a third change of locks to the victims’ house, because the State failed to establish a causal nexus between the thefts by Nellen and the cost to replace the victims’ locks for a third time. I reject both of Nellen’s arguments and accordingly affirm.

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