Ariz. Rev. Stat. § 13-603

Section 13-603(C) requires the trial court to consider the defendant’s economic circumstances when setting the manner of restitution payment.

State v. Nosie · filed 1986-03-13(C)

A.R.S. § 13-603(C) also requires that the trial court consider the economic circumstances of the defendant when determining the manner of payment of restitution.

Section 13-603(C) requires restitution for the victim’s full economic loss; the defendant’s economic circumstances matter when the court sets how it will be paid.

State v. Currie · filed 1986-07-01(C)

We hold that ... the court was correct in ordering the defendant to pay the full amount of the economic loss because that is what is required by the specific language of A.R.S. § 13-603(C). For this determination, the statute does not require the court to consider the economic circumstances of the defendant. ... The trial court must consider the defendant’s economic circumstances in determining the manner of payment.

Section 13-603(C) requires restitution for the victim's full economic loss; a defendant who cannot make the ordered payments may seek a change in the manner of payment upon release from prison.

State v. Vera · filed 1988-10-13(C)

A.R.S. § 13-603(C) requires that a defendant be required to pay restitution in the full amount of the economic loss suffered by the victim. ... In the event appellant is unable to make the restitution payments required by the court, he may petition the court upon his release for a change in the manner of payment.

Under the 1983 and 1984 versions of § 13-603(C), when a defendant is imprisoned, the court sets the restitution amount and payment deadline at sentencing, and the defendant may seek reconsideration after release when the court can assess economic circumstances.

State v. Wilson · filed 1986-08-28(C)

When a sentence of imprisonment is imposed and restitution is ordered, consideration of economic circumstances in setting the amount and manner of payment of restitution under the 1983 version and the manner of payment of restitution under the 1984 version of the statute is better left to the time when the payment of restitution is to begin. At the time of sentencing and imposition of restitution, the trial judge should, based upon evidence reflected in the record, determine and impose the full amount of restitution, and set a time within which that amount should be paid. In accordance with Currie, when the convicted person is released from incarceration, he or she may petition the court for a reconsideration of the restitution order.

Section 13-603(C) authorizes restitution payments to begin during incarceration and requires the court to consider the defendant’s economic circumstances when setting payment terms.

State v. Moore · filed 1988-04-28(C)

It is clear that the court was authorized to order restitution in this case pursuant to A.R.S. § 13-603(C). The amount of the restitution is not questioned. Only the manner of payment is at issue. Under A.R.S. § 13-603(C), the court was required to consider the defendant’s economic circumstances in determining the manner of payment.

Section 13-603(C) permits restitution to an insurer that reimburses a property owner for a loss caused by the defendant’s crime.

State v. Merrill · filed 1983-04-19(C)

With this principle in mind, we find that the mandate of restitution, pursuant to A.R.S. §§ 13-603(C) and 13-901(A), is best fulfilled if “victim” includes the entity suffering the economic loss resulting from appellant’s criminal activity.

Section 13-603(C) limits restitution to victims of the crime and excludes third parties injured by unrelated conduct.

State v. Whitney · filed 1985-12-17(C)

The statute which limits restitution to the “victim of the crime” must therefore necessarily distinguish between victims and third parties.

Section 13-603(C) limits restitution to the victim of the criminal conduct for which the defendant was convicted.

State v. French · filed 1990-05-01(C)

We therefore conclude that the legislature intended the phrase "victim of the crime" to refer to the victim of the criminal conduct for which the defendant was convicted.

Section 13-603 permits restitution to a murder victim’s parents and to an insurer that reimburses a direct victim for losses caused by the crime.

State v. Smith · filed 1992-05-21

This court held that A.R.S. § 13-603 required restitution only to the "victim" of the crime, which did not include the motel owner because he was not the victim of the specific assault conduct of which defendant was convicted. ... In this case, however, the loss for the destruction of the room in which the victim was killed was borne by defendant’s parents, with whom he lived, and who were undeniably "victims” of their son’s murder. ... Additionally, an insurer that reimburses a direct victim for losses incurred as a result of the crime is entitled to restitution. ... Based on this analysis, we find no error in the restitution order imposed.

Section 13-603(C) permits restitution to a county for medical expenses it paid for a defendant injured during his criminal conduct.

State v. Young · filed 1983-07-12(C)

We find that the trial court properly imposed restitution to the Yavapai County Sheriff’s Office for appellant’s medical bills as a condition of probation and therefore affirm the sentence.

Section 13-603(C) does not authorize restitution to a government agency for extradition costs because those prosecution expenses do not make the agency a victim of the crime.

State v. Maupin · filed 1990-04-05(C)

We therefore hold that A.R.S. § 13-603(C) does not confer jurisdiction on the trial court to require a defendant to reimburse a government agency for the costs of extradition.

Section 13-603(C) requires restitution for economic loss to a deceased victim’s immediate family.

State v. Wideman · filed 1990-05-22(C)

Arizona law requires a trial court to impose restitution for economic loss as a part of the defendant's sentencing. In this case, since the victim died, the members of the victim's immediate family are the appropriate parties to whom the defendant must make restitution. A.R.S. § 13-603(C).

Section 13-603(C) provides that restitution remains owed to a victim’s family when the victim dies.

State v. Lopez · filed 1992-12-22(C)

The fact that Anthony died does not extinguish the obligation for restitution. When the victim dies, the restitution is owed to the victim’s family. A.R.S. § 13-603(C). Ordering that restitution be paid directly to the hospital rather than through the mother was within the trial court’s discretion.

Section 13-603(C) permits restitution to an entity that pays a victim’s own loss on the victim’s behalf and stands in the victim’s shoes.

State v. Prieto · filed 1992-03-24(C)

We hold that the department of economic security is entitled to restitution. ... Here, as we did in Merrill, we compensate an entity which stands in the shoes of the victim because it is legally required to suffer the victim’s own precise loss.

Section 13-603(C) permits restitution to an insurer that compensates a deceased victim’s immediate family for economic loss.

State v. Blanton · filed 1993-01-26(C)

We conclude that, after paying $85,000 in the negotiated settlement, American Family took the place of Thomas’s immediate family and is eligible for restitution.

Section 13-603(C) requires restitution for economic losses directly caused by bigamy when the offense was committed against a spouse.

State v. Guadagni · filed 2008-02-29(C)

Following a criminal conviction, the trial court must “require the convicted person to make restitution to the person who is the victim of the crime ... in the full amount of the economic loss.” A.R.S. § 13-603(C). ... Here, Gail and Sarah clearly were victims. ... Accordingly, Gail and Sarah are entitled to restitution for the economic losses they suffered as a direct result of Guadagni’s unlawful marriage.

Section 13-603(C) requires restitution for economic losses directly caused by a crime, including losses suffered by an unconsenting spouse in a bigamy case.

State of Arizona v. Guadagni · filed 2008-02-29(C)

Following a criminal conviction, the trial court must “require the convicted person to make restitution to the person who is the victim of the crime . . . in the full amount of the economic loss.” A.R.S. § 13-603(C). ... Accordingly, Gail and Sarah are entitled to restitution for the economic losses they suffered as a direct result of Guadagni’s unlawful marriage.

Section 13-603(C) permits a police department to be treated as a victim eligible for restitution.

In Re J.U. · filed 2016-11-02(C)

We first reject J.U.’s contention in his reply brief that DPD is not a victim for purposes of restitution. In Guilliams, we ... rejected the defendant’s argument that ADOC was not a victim of the offense of escape for purposes of § 13-603(C). 208 Ariz. 48, ¶ 15, 90 P.3d at 790. Based on the same reasoning, DPD was a victim here.

Section 13-603(C) requires restitution to the person who suffered the economic loss; uncontested information in a presentence report can support identifying that person.

State v. Gamble · filed 2018-11-15(C)

Under Arizona statute, "If a person is convicted of an offense, the court shall require the convicted person to make restitution to the person who is the victim of the crime . . . in the full amount of the economic loss . . . ." A.R.S. § 13-603(C). The person entitled to restitution is the one that suffered an economic loss. ... Because the unobjected to information in the presentence report provides evidence to support the superior court's ... restitution order, we cannot conclude that the superior court abused its discretion.

Section 13-603(C) restitution requires notice at the change of plea hearing, and a stipulated plea sentence must include restitution for it to be imposed.

State v. O'Connor · filed 1985-07-02(C)

By this opinion we are holding that at a change of plea hearing the judge must inform the defendant that restitution may be imposed and that if there is a stipulated sentence in the plea agreement the stipulation must include restitution in order for restitution to be imposed.

Section 13-603(C) requires the court to award a victim the full amount of proven economic loss, so a plea agreement cannot cap restitution without the victim’s consent.

E. H. v. Hon. slayton/state · filed 2020-08-04(C)

And the trial court also lacks authority to enforce a cap because pursuant to § 13-603(C) and A.R.S. § 13-804(B), it must award the victim the amount of proven economic loss.

Section 13-603(C) requires the court to order restitution for the victim’s full economic loss even when payment appears unrealistic.

State v. Ambalong · filed 1986-08-07(C)

This statute is mandatory. We recognize that in many cases the imposition of restitution is not realistic. That does not relieve the trial court of the duty to follow the terms of the statute.

Section 13-603(C) makes restitution mandatory, so omitting it from a plea agreement does not alone invalidate a plea when the defendant was advised of the obligation.

State v. Weston · filed 1987-11-17(C)

However, because A.R.S. § 13-603(C) makes restitution mandatory, State v. Ambalong, 150 Ariz. 380, 723 P.2d 729 (App.1986), defendant should have been aware that it would be required. ... We therefore find no reversible error in the omission of this condition from the plea agreement.

Section 13-603(C) requires courts to order restitution upon conviction in adult prosecutions.

In Re the Appeal in Pinal County Juvenile Action No. J-985 · filed 1987-11-19(C)

A.R.S. § 13-603(C) mandates court-ordered restitution upon conviction in adult prosecutions.

Section 13-603 requires a convicted person to pay restitution to the victim; the state and the courts cannot dispense with that obligation.

State v. Dampier · filed 1987-11-24

The fly in this ointment is that the modified sentence proposed by the state would be an unlawful sentence. A.R.S. § 13-603 requires that a convicted person pay restitution to his victim. That restitution is not the state’s to forego. Just as the trial court cannot appropriately ignore the obligation to award appropriate restitution, neither can the court of appeals.

Section 13-603(C) requires the court to order restitution.

State v. Crowder · filed 1987-12-04(C)

Nevertheless, because A.R.S. § 13-603(C) requires that restitution be ordered, provision was made for it in the plea agreement, as defendant was well aware.

Section 13-603(C) requires restitution in all criminal cases.

State v. Marchesano · filed 1989-06-13(C)

Restitution is required in all criminal cases. See A.R.S. §§ 13-603(C) and 13-804. However, the state did not cross-appeal, and therefore we do not disturb this order.

Section 13-603(C) permits a court to order restitution without imposing a fine.

State v. Pleasant · filed 1985-05-23(C)

We hold the court could properly order restitution without a fine pursuant to § 13-603(C), and find no error.

Under the pre-1986 version of § 13-603(C), restitution exceeding the offense’s statutory monetary limits requires the defendant’s voluntary and intelligent agreement to the higher amount, clearly shown in the record.

State v. Lukens · filed 1986-11-20(C)

We hold that a defendant cannot be required to pay restitution in an amount exceeding statutorily-prescribed monetary parameters of the crime to which he pleads guilty unless he voluntarily and intelligently agrees to pay a higher amount. The record must clearly reveal that any agreement to pay a higher amount was voluntarily and intelligently made.

Section 13-603(C) requires restitution for the victim’s full economic loss and allows it to be imposed when a defendant is sentenced after probation is revoked.

State v. Holguin · filed 1993-05-04(C)

The trial court is required to impose restitution to reimburse the victim for the full amount of his economic loss. A.R.S. § 13-603(0). Although the statute is silent as to when restitution must be assessed, generally it is ordered at the time of sentencing. ... It follows then that the assessment of restitution at a sentencing proceeding after the failure to complete a suspended sentence is appropriate.

Section 13-603(C) requires the court to order restitution for a crime victim’s full economic loss.

State v. Contreras · filed 1994-05-17(C)

A trial court is required by Arizona Revised Statutes Annotated ("A.R.S.") section 13-603(C) to impose restitution to reimburse the victims of crime for their full economic loss.

Section 13-603(C) requires the court to order restitution when a victim substantiates a timely claim.

State v. ZAPUTIL · filed 2008-11-10(C)

Under the circumstances, there is no basis for the trial court not ordering restitution in compliance with A.R.S. § 13-603(C).

Section 13-603(C) entitles victims, their families, and certain other entities to restitution for the full amount of economic loss determined by the court.

State v. Calderon · filed 2017-09-26(C)

Victims, their families, and certain other entities are entitled to restitution “in the full amount of the economic loss as determined by the court.” A.R.S. § 13-603(C); ... Under these circumstances, the State satisfied its burden of proof, and the superior court properly awarded restitution.

Section 13-603(C) requires restitution for the full amount of a victim’s economic loss caused by the crime.

E.H. v. Slayton · filed 2019-03-14(C)

Once E.H. files a claim, the superior court must order the defendants to make restitution for the full amount of economic loss caused to E.H. by the crimes the defendants committed against her brother.

Section 13-603(C) makes restitution mandatory; omitting it is sentencing error.

State v. Perez · filed 2025-01-09(C)

The superior court did not order restitution. Restitution is mandatory. A.R.S. § 13-603(C); State v. Lindsley, 191 Ariz. 195, 197 (App. 1997). Despite this error, “we will not correct sentencing errors that benefit a defendant, in the context of his own appeal, absent a proper appeal or cross-appeal by the [S]tate.” State v. Kinslow, 165 Ariz. 503, 507 (1990).

Section 13-603(C) requires payment of full economic restitution to the victim.

Federal Deposit Insurance v. Colosi · filed 1998-11-19(C)

Payment of full economic restitution is mandatory under the Arizona sentencing system.

Section 13-603(C) requires restitution for a victim’s economic loss; the record must support the amount awarded and identify who is entitled to receive it.

State v. Zamora · filed 2018-02-27(C)

Here, nothing in the record indicates what relationship, if any, the $550 ordered as restitution has to the Victim’s economic loss, and it is not clear who is entitled to restitution. ... On this record, we cannot affirm an award of restitution. Accordingly, the trial court fundamentally erred, and we vacate the restitution order of $550.

Section 13-603(C) requires restitution for economic loss directly caused by the convicted offense, even when the defendant was acquitted of a separate charge involving the victim.

State of Arizona v. Lewis · filed 2009-07-23(C)

Thus, although Lewis was acquitted of aggravated assault, he may still be liable for restitution as long as his criminal conduct—the drive-by shooting—directly caused A.’s injuries.

Section 13-603(C) does not authorize restitution for consequential contract damages rather than economic loss caused by the offense.

State v. Pearce · filed 1988-02-25(C)

As we discussed above, we do not believe that A.R.S. § 13-603(C) contemplates the award of contract damages made by the trial court. We remand for a determination of the economic loss actually suffered by Woudenberg as a result of the theft consistent with this opinion.

Section 13-603(C) requires restitution for the victim’s full economic loss, including unpaid medical expenses that an insurer may later cover.

State v. Steffy · filed 1992-10-01(C)

As we have previously pointed out, restitution of full economic loss to the victim of a crime is mandatory under our sentencing scheme.

Section 13-603(C) requires the sentencing court to determine the victim’s economic loss and order restitution in that amount.

State v. Scroggins · filed 1991-05-02(C)

More importantly, A.R.S. § 13-603(C) imposes upon the trial court an affirmative duty to determine the amount of the victim’s economic loss and to order restitution in that amount.

Section 13-603(C) requires restitution for the victim’s full economic loss, even when that loss exceeds the monetary limit of the offense of conviction.

State v. Fancher · filed 1991-10-01(C)

As noted, a trial court has the authority and obligation to order restitution to the victim “in the full amount of the economic loss.” A.R.S. § 13-603(C).

Section 13-603(C) requires restitution for the full amount of a victim’s economic loss, including reasonably anticipated future losses caused by the offense.

State v. Howard · filed 1991-07-18(C)

The legislature’s enactment of A.R.S. § 13-603(C), a mandatory restitution statute, reflects its sense of responsibility for victims. ... We hold that the full amount of a victim’s economic loss includes not only those losses incurred at the time of sentencing, but also those losses reasonably anticipated to be incurred in the future as a result of the defendant’s actions.

Section 13-603(C) generally measures restitution for lost personal property by its fair market value at the time of loss, but permits another measure when needed to make the victim whole.

State v. Ellis · filed 1992-03-10(C)

In this case, we hold that in assessing restitution for a loss of personal property, the measure of the victim's full economic loss is the fair market value of the property at the time of the loss. The judge has discretion to use other measures of economic loss when fair market value will not make the victim whole.

Section 13-603(C) requires restitution to victims, but paying restitution for stolen goods does not give the offender title to them.

State v. Freeman · filed 1993-03-18(C)

As we have often noted, the payment of restitution to victims is mandatory under our sentencing system. ... Contrary to defendant’s contentions, therefore, payment of restitution is neither intended to, nor does, create valid legal title in the stolen goods.

Section 13-603(C) requires restitution for the victim’s full economic loss, but that amount does not include interest imposed on the restitution award.

State v. Foy · filed 1993-09-16(C)

We hold in this opinion that restitution for the full economic loss to the victim under Ariz.Rev.Stat.Ann. (“A.R.S.”) section 13-603(C) ... does not include payment of interest on restitution amounts ordered by the trial judge as a condition of probation.

Section 13-603(C) limits restitution to economic loss and excludes consequential damages that do not flow directly and immediately from the defendant’s conduct.

State v. Sexton · filed 1993-09-23(C)

“Economic loss” as defined in A.R.S. § 13-105(11) and as used in A.R.S. § 13-603(C) is equivalent to “actual damages” which are defined as: ... The term “economic loss” in the context of the restitution a court may order expressly excludes consequential damages.

Section 13-603(C) requires restitution for a victim’s economic loss but does not authorize restitution for pain and suffering.

State v. Carbajal · filed 1994-01-13(C)

Here, the trial court’s comments indicate the restitution order was made to compensate the victims for “their emotional and their mental health, their sorrow and their neglect.” In other words, restitution was awarded as damages for pain and suffering, not for “economic losses” suffered by the victims. Arizona law does not authorize restitution for such losses. Accordingly, the restitution order was improper and must be remanded.

Section 13-603(C) requires restitution for the full amount of a victim’s economic loss, including reasonable interest and fees incurred to finance necessary treatment caused by the offense.

In Re Brendan G. · filed 2009-04-02(C)

Pursuant to A.R.S. § 13-603(C) (2001), courts must award restitution "in the full amount of the [victim's] economic loss ...." ... As to the CreditCare account, we hold that the interest and fees constitute an economic loss within the meaning of A.R.S. § 13-105(16).

Section 13-603 requires restitution only for losses caused by the criminal conduct for which the defendant was convicted.

State Ex Rel. McDougall v. Superior Court · filed 1996-07-17(C)

The state’s argument is contrary to the plain language of both the Arizona Constitution and A.R.S. §§ 13-603(0 and 13-804. Both the constitution and statutes require restitution only where the injury is caused by the criminal conduct for which defendant was convicted. We, therefore, hold Martinez’ liability for the underlying-accident does not require restitution as part of Martinez’ sentence for leaving the scene of the accident.

Section 13-603(C) permits restitution to victims of the offenses for which the defendant was convicted, but not to people whose losses arose from uncharged transactions.

State v. Proctor · filed 1998-09-08(C)

Conversely, we find the sellers in the uncharged transactions were not victims pursuant to § 13-603(C), nor did their economic loss stem from the criminal offenses of which appellants were convicted.

Section 13-603(C) requires restitution for economic loss directly caused by the defendant’s criminal conduct, without an intervening cause.

State v. Wilkinson · filed 2002-02-14(C)

We hold, therefore, that the statutes direct a court to award restitution for those damages that flow directly from the defendant’s criminal conduct, without the intervention of additional causative factors.

Section 13-603(C) requires restitution for reasonable travel expenses incurred by a murder victim’s children who voluntarily attend the trial.

State v. Madrid · filed 2004-03-18(C)

In Arizona, a person convicted of a criminal offense is required to pay restitution to any victim that has suffered an economic loss. A.R.S. § 13-603(C) (2003). ... Accordingly, we conclude that the travel expenses relating to the children’s voluntary attendance at Madrid’s trial constitute an economic loss for which they are entitled to restitution.

Section 13-603(C) does not allow restitution for a government agency’s routine costs of investigating a crime, even when the crime caused that work.

State v. Guilliams · filed 2004-05-28(C)

We are struck by how most of these latter costs are similar to, if not indistinguishable from, the normal costs of investigating any crime and arresting and capturing the suspect. ... We decline to construe the restitution laws to encompass costs incurred by governmental entities that are performing their routine functions, regardless of whether those costs can be traced back to a criminal act.

Section 13-603(C)’s full economic loss measure can include a vehicle loan payoff shortfall when fair market value would leave a directly caused loss uncompensated.

In Re William L. · filed 2005-09-15(C)

The juvenile court correctly perceived that the primary purpose of restitution — to make the victim whole — would have been frustrated if the measure of recovery was limited to fair market value. Based on the facts of this case, the court did not abuse its discretion by ordering juvenile to pay as restitution the entire amount by which the encumbrance on the car exceeded the insurance payout.

Section 13-603(C) entitles a victim to restitution for the full economic loss determined by the court; uncontested information in a presentence report can support the amount awarded.

State v. Dixon · filed 2007-07-11(C)

A victim is entitled to restitution “in the full amount of the economic loss as determined by the court.” A.R.S. § 13-603(C). ... Although the evidence of value and absence of insurance coverage for the listed items contained in the presentence report was uncorroborated by other evidence, it was nonetheless uncontested evidence that was “substantiated” by the victims’ claims.

Section 13-603(C) requires an unlicensed contractor to repay all payments received under the contract as restitution, unless those payments were previously refunded.

TOWN OF GILBERT PROSECUTOR'S OFC. v. Downie · filed 2007-07-24(C)

In other words, all payments made by victims to an unlicensed contractor under a contract, unless previously refunded, constitute economic loss subject to restitution.

Section 13-603(C) requires restitution of all payments victims made under a contract with an unlicensed contractor, unless those payments were previously refunded.

Town of Gilbert Prosecutor's Office v. Downie · filed 2007-07-24(C)

In other words, all payments made by victims to an unlicensed contractor under a contract, unless previously refunded, constitute economic loss subject to restitution.

Section 13-603(C) requires restitution for a victim’s economic loss, accounting for any value the defendant conferred on the victim.

Town of Gilbert Prosecutor's Office v. Downie · filed 2008-08-04(C)

In Wilkinson, we identified a three-part test for determining which losses qualify for restitution under § 13-603(C). ... We are persuaded that determining a victim's "loss" requires consideration of any benefits conferred on the victim.

Section 13-603(C) requires restitution for a victim’s economic loss, with any value conferred on the victim considered in calculating that loss.

Prosecutor v. Hon. downie/matykiewicz · filed 2008-08-04(C)

We are persuaded that determining a victim’s “loss” requires consideration of any benefits conferred on the victim.

Section 13-603 does not allow restitution for a victim’s family member’s attorney fees for assisting the prosecution when those fees do not flow directly from the offense.

State v. Slover · filed 2009-02-09(C)

Under A.R.S. § 13-603(0, a person convicted of an offense must “make restitution to the ... immediate family of the victim if the victim has died, in the full amount of the economic loss as determined by the court.” ... Those fees were therefore consequential rather than direct damages arising from Slover’s crime and not recoverable as restitution under Aizona statute.

Section 13-603(C) requires the sentencing court to determine the victim’s economic loss and order restitution in that amount as part of sentencing.

State v. Wiggins · filed 2014-07-24(C)

Section 13-603 imposes an affirmative duty on the superior court to determine the amount of the victim’s economic loss and order restitution in that amount, which should be done as part of sentencing.

Section 13-603(C) requires restitution for the full amount of a victim’s economic loss, including boat storage fees directly caused by the offense.

State v. Marquez · filed 2017-10-26(C)

Following Marquez’s conviction, the superior court was required to order restitution to the Victim “in the full amount of the economic loss” as determined by the court. A.R.S. § 13-603(C). ... Accordingly, the superior court did not err in ordering restitution for Victim’s boat storage fees.

Section 13-603(C) requires restitution for the full amount of economic loss, which can include security improvements directly caused by the offense.

In Re Tommy G. · filed 2021-05-18(C)

A court must “require the convicted person to make restitution . . . in the full amount of the economic loss as determined by the court.” A.R.S. § 13-603(C). ... Thus, the trial court did not err by concluding that Tommy’s part in the vandalism was a direct cause of the expense devoted to the anti-vandal pulls. The cost of the pulls was an economic loss, appropriate as restitution.

Section 13-603(C) requires restitution for a victim’s full economic loss, including payments obtained through theft or fraud that provided the victim no value.

State v. Matzdorff · filed 2021-09-23(C)

By statute, the superior court “shall require” a person “convicted of an offense” to pay “restitution to the person who is the victim of the crime . . . in the full amount of the economic loss as determined by the court.” A.R.S. § 13-603(C). ... The record supports the court’s findings that Matzdorff was not contractually entitled to the “commission” payments, her receipt of those funds was attributable to her commission of theft or fraud, and the payments provided no value to the victims. ... The record supports the court’s findings that the “overhead” payments arose from Matzdorff’s commission of theft or fraud and that they did not provide benefit to the victims.

Section 13-603(C) requires restitution for the full amount of economic loss, including security camera costs directly caused by the offense.

In Re Brigham H. · filed 2021-10-07(C)

A court must “require the convicted person to make restitution . . . in the full amount of the economic loss as determined by the court.” A.R.S. § 13-603(C). ... As a result, the criminal conduct caused the installation cost directly, and restitution was appropriate.

Section 13-603(C) requires restitution for the victim’s full economic loss caused by the offense, even when the loss exceeds the dates or amounts stated in the indictment.

State v. Mercer · filed 2015-01-29(C)

Such a proposition would run counter to the requirement that the court award restitution to a victim for the full economic loss suffered by the victim as a result of the defendant’s actions, see A.R.S. §§ 13-603(C), -804(B), and we see no reason to mechanically limit restitution awards to the dates or amounts specified in the indictment.

Section 13-603(C) requires restitution for the full economic loss determined by the court and sets no statutory maximum that limits restitution to the jury’s valuation finding.

State of Arizona v. Leon · filed 2016-08-29(C)

Because there is no “statutory maximum” or “mandatory minimum” applying to restitution that can be ordered under § 13- 603(C), we conclude the Apprendi rule is inapplicable.

Section 13-603(C) limits restitution to the victim’s economic loss; amounts the victim owed the defendant for the work must be deducted unless the defendant already received them.

State v. Mullet · filed 2018-11-20(C)

In other words, if Mullet had never misappropriated any funds, Lawson would have been entitled to the full amount of the customers’ payments minus Mullet’s commission. Accordingly, Lawson did not suffer an economic loss based on the portion of the payment that otherwise would have been designated as Mullet’s commission. Under these circumstances, requiring Mullet to forfeit the commission that Lawson owed Mullet based on the work provided would amount to disgorgement and would serve only to further punish Mullet. Such additional punishment is beyond the appropriate scope of criminal restitution laws.

Section 13-603(C) does not allow restitution for routine costs of investigating a crime, including a forensic examination conducted for use at trial.

State v. Linares · filed 2017-01-10(C)

A person convicted of an offense must pay restitution “to the person who is the victim of the crime.” A.R.S. § 13-603(C). ... Simply because the MCAO contracted out part of its investigative function to a forensic examiner does not make the costs for such a forensic examination for later use at trial an expense entitling the State to restitution.

Section 13-603(C) requires restitution for a victim’s full economic loss, accounting for insurance payments already received so the victim does not recover twice.

State v. Hayes · filed 2017-07-18(C)

A person convicted of a criminal offense is required to pay restitution to a victim of the crime “in the full amount of the economic loss as determined by the court.” A.R.S. § 13-603(C) (2010); ... The statutory restitution scheme requires a defendant to pay the “full economic loss,” not double the full economic loss.

Section 13-603(C) requires restitution for a victim’s full economic loss, which may include home security costs incurred for a reasonable period to restore the victim’s sense of security.

State v. Quijada · filed 2019-03-28(C)

Under A.R.S. § 13-603(C), a court is required to order restitution to victims of crimes “in the full amount of the economic loss as determined by the court.” ... With this framework in mind, we conclude the expenses associated with installing a home security system may be recoverable as restitution if they were incurred “in an effort to restore the victim’s equanimity” following the criminal offense. ... A defendant may not be held responsible for the costs of maintaining a home security system beyond a reasonable period necessary to restore the victim’s equanimity.

Section 13-603(C) permits restitution for costs caused by retaining a victim's vehicle as evidence when the retention directly follows from the defendant's criminal conduct.

State v. Bartels · filed 2020-08-06(C)

The retention of evidence in furtherance of obtaining a criminal conviction was a natural consequence of Bartels' criminal conduct. ... Reviewing the record in this way, we do not find the duration of the impound, in this case, was an intervening factor rendering restitution inappropriate.

Section 13-603(C) requires full restitution for a victim’s economic loss, which may include attorney fees incurred as a result of the crime.

State v. Reed · filed 2020-10-20(C)

A person convicted of a crime is required to make restitution “in the full amount of the economic loss as determined by the court.” A.R.S. § 13-603(C); accord A.R.S. § 13-804 (authorizing restitution award “to any person who suffered an economic loss caused by the defendant’s conduct”). ... On this record, Reed’s counsel has failed to show the superior court erred in finding the attorneys’ fees were economic loss and therefore recoverable as restitution.

Section 13-603(C) permits restitution for a victim’s attorney fees when an attorney is reasonably necessary to enforce the victim’s rights in the criminal case.

State of Arizona v. Reed · filed 2022-02-01(C)

Similarly, when a victim retains an attorney to enforce her rights in the criminal proceedings, the court should order payment of those fees as restitution when attorneys are reasonably necessary to enforce these rights.

Section 13-603(C) requires restitution for economic loss, but future lost wages must have a reasonable basis for calculation and a direct causal link to the crime.

E.H. v. Slayton · filed 2024-08-08(C)

A convicted person is required to make restitution to the victim of the crime “in the full amount of the economic loss as determined by the court.” A.R.S. § 13-603(C). ... The trial court thus did not abuse its discretion in finding that J.H.’s future lost wages were consequential damages not subject to restitution.

Section 13-603(C) does not require a crime victim to obtain a mental health diagnosis before requesting restitution.

G.F. v. Nielson · filed 2024-09-03(C)

Arizona law does not require crime victims to obtain a mental health diagnosis before restitution is requested. See A.R.S. §§ 13-603(C), -105(16).

Section 13-603(C) requires restitution for the victim’s full economic loss caused by the offense.

State v. Bartik · filed 2021-10-21(C)

Arizona law requires the trial court order restitution for the full economic loss to the victim. ... The trial court could reasonably infer that the evidence underlying Bartik’s conviction, namely her unlawful possession of the jewelry, directly resulted in D.K.’s economic loss.

Section 13-603(C) requires restitution for a victim’s full economic loss, and an uncontested presentence report may support the amount awarded.

State of Arizona v. Dixon · filed 2007-07-11(C)

A victim is entitled to restitution “in the full amount of the economic loss as determined by the court.” A.R.S. § 13-603(C). ... Indeed, the statutory sentencing scheme implies that the presentence report and victim impact statement will provide restitution information for the sentencing court’s consideration.

Section 13-603(C) limits restitution to the victim’s economic loss attributable to the defendant.

State v. Lang · filed 2018-03-15(C)

Lang argues the $3,693 restitution award was error, because the “full amount of the economic loss” for restitution totaled $2,127.03. See A.R.S. § 13-603(C)(2018). ... This court accepts the State’s confession of error, and reduces the restitution award from $3,693 to $2,127.03.

Section 13-603(G) cannot be applied to revoke licenses needed to distribute protected material after an obscenity conviction, but it permits revocation of a license unrelated to that activity.

State v. Bauer · filed 1988-12-13(G)

No such construction of § 13-603(G) is possible. It operates to bar the defendants from all future dissemination by revoking their licenses to do business. ... We hold that the revocation of defendants’ essential operating permits and license to disseminate materials which fall within the ambit of the First Amendment acts as an unlawful prior restraint.

Section 13-603(C) requires restitution for the victim’s economic loss, but does not require payment for expenses already covered by a civil settlement.

State v. Howard · filed 1989-10-05(C)

The net effect of cross appellant’s request would be to award the victim an amount in excess of that intended by the legislature. The purpose of mandatory restitution is to make the victim whole, not to punish.

Section 13-603(C) allows a civil settlement to satisfy or reduce restitution to the extent it compensates the victim’s family for economic loss.

State v. Andersen · filed 1993-07-20(C)

Settlement of a civil lawsuit may extinguish a defendant’s restitution obligation to the extent that the settlement compensates the victim’s family’s economic loss.

Section 13-603(C) requires restitution for the victim’s full economic loss, with credit for civil payments that compensate that loss.

State v. Iniguez · filed 1991-04-11(C)

In short, although the court must consider all economic losses of the victim under A.R.S. § 13-804(B), and must require the offender to make restitution in the full amount of economic loss under A.R.S. § 13-603(C), it should not order restitution exceeding the victim's actual economic losses after crediting payments received by the victim outside the criminal proceeding.

Section 13-603(H), read with the sentencing rules and credit statute, requires the sentencing judge to calculate and announce presentence custody credit at sentencing in the defendant’s presence.

State v. Nieto · filed 1991-11-19(H)

A.R.S. § 13-603(H) states: ... A court authorized to pass sentence upon a person convicted of any offense defined within or without this title shall have a duty to determine and impose punishment proscribed for such an offense. ... Thus, the rules and statutes cited above make it abundantly clear that the sentencing judge has the duty and responsibility of computing and pronouncing the presentence custody credit at the time of sentence in the presence of the defendant.

Section 13-603(A)'s sentencing requirement does not apply when judgment of guilt has been deferred.

State v. Perez · filed 1992-02-27(A)

This section is inapposite. It says “shall be sentenced.” Under our rules, a sentence is defined as being entered after judgment of guilt. In this case judgment of guilt was deferred in accordance with § 13-3601(G).

Section 13-603(B) makes a probationary sentence tentative for alteration or revocation under chapter 9, but a final judgment of conviction for other purposes.

State v. Albe · filed 1984-11-13(B)

A.R.S. § 13-603(B) provides: If a person is convicted of an offense, the court, if authorized by chapter 9 of this title, may suspend the imposition or execution of sentence and grant such person a period of probation except as otherwise provided by law. The sentence is tentative to the extent that it may be altered or revoked in accordance with chapter 9 of this title, but for all other purposes, it is a final judgment of conviction. ... In addition, there was no stay of the sentence in this case and the trial court retained jurisdiction to revoke appellant’s probation.

Section 13-603(A) makes a specific statutory sentencing range govern when one applies; otherwise, the sentencing ranges in chapters 6 through 9 apply.

State v. Tarango · filed 1996-04-16(A)

Rather, we interpret former § 13-603(A) to mean that where a statute specifies a particular range of sentencing, that statute shall govern. [2] Otherwise chapters 6-9 of title 13 shall provide the range of sentencing.

Section 13-603(K) permits a court to allow a defendant to seek commutation of a mandatory sentence the court finds clearly excessive, without violating separation of powers.

State v. Jackson · filed 1996-03-28(K)

A.R.S. section 13-603(K), therefore, is entirely consistent with the constitution’s distribution and separation of powers.

Section 13-603(K) requires a trial court that finds a mandatory sentence clearly excessive to enter a special order stating its reasons in writing and forward it to the board of executive clemency; failure to do so is reversible error.

State v. Garza · filed 1997-07-15(K)

In this opinion, we hold that when, pursuant to Ariz.Rev.Stat.Ann. (“A.R.S.”) section 13-603(K) (Supp.1996), a trial court finds that a sentence is clearly excessive, it must enter a special order with specific written reasons for its finding and forward the order to the board of executive clemency. We further conclude that the court’s failure to enter such an order is reversible error.

Section 13-603(I) requires a term of community supervision after imprisonment even when the prisoner must serve the full prison sentence.

State v. Jenkins · filed 1998-08-06(I)

The plain language of A.R.S. section 13-603(1), read in conjunction with the related statutes, indicates the Legislature’s intent to require a term of community supervision for all prisoners, whether or not they are eligible for early release.

Section 13-603(I) determines the length of community supervision, and subsection (J) requires the resulting term to be expressed in months or years.

State v. Razo · filed 1999-10-21(I), (J)

Applying those principles to § 13-603(1) and (J), we find that subsection I provides the means of calculating the length of the term of community supervision, while subsection J describes how the resulting calculation shall be expressed.

Section 13-603(I) requires a felony offender’s community supervision to follow imprisonment; the term cannot be served while the offender is incarcerated for a later conviction.

State v. Cowles · filed 2004-01-08(I)

The controlling provisions are A.R.S. §§ 13-105(4), 13-603(I) and 41-1604.07(F). The plain language of A.R.S. § 13-105(4), read in conjunction with the related statutes, indicates that Cowles’ community supervision term for the Maricopa County conviction could not have been served while he was incarcerated for the Navajo County conviction.

Section 13-603(I) authorizes a consecutive community-supervision term of one day for every seven days of the sentence.

State v. Clayborn · filed 2016-08-04(I)

The term of community supervision, imposed consecutively, was appropriate under A.R.S. § 13-603.I.

Section 13-603(K) permits a sentencing court to waive community supervision after a prison sentence for one count when it imposes consecutive probation for another count.

State v. Thayer · filed 2017-02-23(K)

A sentencing court may waive community supervision after a prison sentence for one count if the court imposes a consecutive term of probation for another count. A.R.S. § 13-603(K) (2016).

Section 13-603(I) requires a term of community supervision after imprisonment to be served consecutively to the actual period of imprisonment.

State v. Peve · filed 2017-06-01(I)

But he offers no support for his contention that under Arizona law, community supervision is served concurrently with a prison sentence. See A.R.S. § 13-603(I) (2017) ("If a person is convicted of a felony offense and the court sentences the person to a term of imprisonment, the court at the time of sentencing shall impose on the convicted person a term of community supervision. The term of community supervision shall be served consecutively to the actual period of imprisonment . . . .").

Section 13-603(I) requires a court sentencing a person convicted of a felony to imprisonment to impose a term of community supervision.

State v. Worrell · filed 2017-08-08(I)

The trial court was required to impose a term of community supervision pursuant to A.R.S. § 13-603(I), which states: “if a person is convicted of a felony offense and the court sentences the person to a term of imprisonment, the court at the time of sentencing shall impose on the convicted person a term of community supervision.”

Under the 1996 version of § 13-603(J), fractional months of community supervision must be rounded to the nearest month, whether up or down.

Shadid v. State · filed 2018-04-26(J)

The version of § 13-603(J) in effect in 1996 unambiguously requires rounding to the nearest month, and uses the word "may" only in clarifying that fractional months "may be" rounded either up or down "to the nearest month." 1995 Ariz. Sess. Laws, ch. 199, § 2.

When prison terms run concurrently, the defendant serves one community supervision term based on those concurrent terms.

State v. Williams · filed 2019-09-05(I)

Third, our review of the sentencing minute entry does not indicate the superior court ordered consecutive terms of community supervision. Rather, upon his release, Williams will serve one term of community supervision, the duration of which will be based on the imposed concurrent terms of imprisonment. See A.R.S. § 13-603(I).

Section 13-603(I) makes community supervision consecutive to imprisonment and distinct from it.

State v. Muehlhausen · filed 2020-11-10(I)

Community supervision is consecutive to imprisonment, A.R.S. § 13-603(I), and is not equivalent to imprisonment.

Section 13-603(I) requires the court to impose community supervision as part of a felony prison sentence; the corrections department cannot add a term the court omitted from a final sentence.

State v. Price · filed 2021-07-27(I)

And while community supervision is mandatory under Arizona law, see State v. Jenkins, 193 Ariz. 115, 119, ¶ 11 (App. 1998), the court must impose it as part of the sentence, see A.R.S. § 13-603(I). Thus, the superior court erred when it concluded that community supervision is not part of Price’s sentence, and that it was “mandatory” even if the court “fail[ed] to reference it.”

Section 13-603(I) requires a term of community supervision even after a flat-time sentence for second degree murder.

State v. House · filed 2017-02-02(I)

A sentencing court must include a term of community supervision even for a “flat-time” sentence for second degree murder.

Section 13-603(I) makes community supervision consecutive to imprisonment, so the term begins only if the defendant is released from prison.

Hylton v. Shinn · filed 2025-05-08(I)

Thus, the community supervision term is separate from the term of imprisonment and begins only if the defendant is released from prison.

Section 13-603(I) permits a term of community supervision to follow a calendar-year prison term.

State v. Gray · filed 2026-05-07(I)

First, a term of community supervision may legally follow a term of imprisonment even when the sentence is a calendar-year term. See State v. Jenkins, 193 Ariz. 115, 118–20 ¶¶ 7–14 (App. 1998); A.R.S. § 13-603.I.

Section 13-603(K) allows a court to waive community supervision when it sentences a person to consecutive probation immediately after imprisonment.

State v. Walls-Bey · filed 2024-11-07(K)

In fact, the superior court’s decision to waive community supervision benefited Walls-Bey because it reduced the sentence imposed for the 2022 matter. Rather than having to complete community supervision in the 2022 matter before starting probation in the 2020 matter, Walls-Bey’s probation term began immediately after his release from prison. See A.R.S. § 13-603(K) (authorizing the court to waive community supervision “if the court sentences a person to serve a consecutive term of probation immediately after the person serves a term of imprisonment”).

Section 13-603(L) allows a court that finds a mandatory sentence clearly excessive to permit the defendant to petition the governor for commutation, but the court must impose the sentence.

State v. Monaco · filed 2004-01-22(L)

Even if a trial court concludes that the mandated sentence is clearly excessive, the court must still impose the sentence but ... may allow the defendant to petition the governor for commutation of the sentence.

When a court finds a legally required sentence clearly excessive, subsection (L) requires a special order allowing a commutation petition, written reasons, and an opportunity for the state and victim to submit statements; failure to comply is reversible error.

State v. Alaniz-Silva · filed 2015-06-23(L)

Failure to comply with A.R.S. § 13-603(L) after finding a sentence clearly excessive is reversible error.

Section 13-603(C) requires a convicted person to pay restitution to the court clerk for disbursement to the victim.

State v. Hansen · filed 2006-11-16(C)

As set forth in A.R.S. § 13-603(C), restitution owed by a convicted person to a crime victim must “be paid to the clerk of the court for disbursement to the victim[.]”

Section 13-603(C) allows a court to determine how restitution is paid when a defendant is outside DOC custody, but does not authorize the court to control deductions from a prisoner’s accounts.

State v. Stocks · filed 2011-06-09(C)

Although A.R.S. §§ 13-603(C) and 13-804(E) give the court authority to determine the manner in which restitution is to be paid when a defendant is not in the custody of DOC, neither statute vests the trial court with authority to control, manage or disburse monies deposited in a defendant’s accounts while he is in prison or the power to order DOC to deduct monies from inmate accounts contrary to DOC’s comprehensive statutory obligations.

Section 13-603(C) provides a right to restitution that may be waived when a claim misses a reasonable court-imposed deadline.

State v. Nuckols · filed 2012-04-12(C)

Here, the untimeliness of the request waived the restitution to which Pima County otherwise was constitutionally and statutorily entitled.

A trial court may set a reasonable deadline for restitution claims, and missing that deadline waives restitution otherwise available under § 13-603(C).

State of Arizona v. Nuckols · filed 2012-04-12(C)

“[A] trial court may impose a reasonable deadline within which restitution claims must be filed.” ... Victims who fail to “present their restitution claims and supporting evidence” by such a deadline waive their rights to receive restitution. ... Here, the untimeliness of the request waived the restitution to which Pima County otherwise was constitutionally and statutorily entitled.

Section 13-603(C) sets no deadline for claiming restitution, though the superior court may set a reasonable deadline.

E.H. v. Slayton · filed 2021-04-20(C)

No rule or statute imposes a deadline for claiming restitution. See, e.g., State v. Holguin, 177 Ariz. 589, 591 (App. 1993) (“Although [subsection 13-603.C] is silent as to when restitution must be assessed, generally it is at the time of sentencing.”). The superior court, however, may set a reasonable deadline for filing a restitution claim.

Section 13-603(C) requires restitution but does not require the court to assess it at sentencing.

State v. Grijalva · filed 2017-03-07(C)

In contrast, A.R.S. § 13-603(C), which requires the trial court to impose restitution, “is silent as to when restitution must be assessed,” notwithstanding that restitution generally “is ordered at the time of sentencing”—if the court has “sufficient evidence at that time” to support a restitution award.

Section 13-603(C) requires restitution for the victim’s full economic loss and sets no deadline for assessing it.

State v. Jackson · filed 2018-03-22(C)

Because A.R.S. § 13-603(C) is silent as to when restitution must be assessed, and A.R.S. § 13-805 grants the trial court jurisdiction “until [court-ordered payments] are paid in full or until the defendant’s sentence expires,” we hold the court here retained jurisdiction to impose additional restitution because Jackson’s sentence had not yet expired.

Section 13-603(C) requires restitution for the full amount of a victim’s economic loss and allows an additional award for losses incurred after sentencing while the defendant is serving the sentence.

State v. Cervantes · filed 2019-07-30(C)

However, nothing in the text of the statute supports the proposition that A.R.S. § 13-805 limits the court’s authority to award restitution under A.R.S. § 13-603 or the victim’s right to full restitution under Article 2, Section 2.1(A)(8) of the Arizona Constitution. Therefore, to fulfill the court’s mandate—to make the victim whole from the economic losses caused by Cervantes’ criminal conduct—the court properly exercised jurisdiction over the request for additional restitution.

Section 13-603(C) requires restitution for the full amount of a victim’s economic loss and permits the court to award it after sentencing.

State v. Ames · filed 2025-05-20(C)

Section 13-603 provides that the court is both required to and has the authority to award restitution for the “full amount” of a victim’s losses, but does not speak to “when restitution must be assessed.” State v. Grijalva, 242 Ariz. 72, 74, ¶ 9 (App. 2017) (emphasis added) (citation omitted). We have interpreted this to mean that restitution may be ordered at a time after sentencing.

Section 13-603(C) is one basis for criminal restitution, but § 13-804 also authorizes restitution.

State v. Leal · filed 2019-11-21(C)

Moreover, legislation after Merrill confirms King’s directive that restitution may be ordered under either A.R.S. § 13-603(C) or § 13-804.

Section 13-603(C) requires a conviction before a court may order restitution under that provision.

State v. Mata · filed 2024-05-23(C)

Section 13-603(C) expressly requires that a conviction exist before ordering a defendant to make restitution.

Section 13-603(C) allows restitution for a murdered child’s future lost wages when the crime directly caused the loss and the amount can be reasonably estimated.

E. H. v. Slayton · filed 2025-04-30(C)

This Court has not previously addressed whether yet-to-be-incurred losses, like future lost wages, qualify as “economic loss” under § 13-603(C), making them recoverable as restitution. ... In sum, future economic losses, including lost earnings, can be awarded as restitution if they satisfy the Wilkinson test.

Section 13-603(C) permits restitution for the future cost of raising a murder victim’s children until age 18 when that cost is directly caused by the crime, but not for costs after they turn 18.

State v. Davis · filed 2026-05-20(C)

By statute, “the court shall require the convicted person to make restitution to the person who is the victim of the crime or to the immediate family of the victim if the victim has died, in the full amount of the economic loss as determined by the court and in the manner as determined by the court or the court’s designee.” A.R.S. § 13-603(C) (emphasis added); see also A.R.S. § 13-804(B) (“In ordering restitution for economic loss . . . , the court shall consider all losses caused by the criminal offense or offenses for which the defendant has been convicted.”). ... Therefore, this court vacates that portion of the order requiring Davis to pay restitution for the costs of raising the children after they turn 18 years of age. ... On this record, and following the Arizona Supreme Court’s directive in E.H., Davis has not shown the superior court erred in denying his PCR petition challenging the restitution award for the cost of raising the children until they turn 18 years of age.