Court of Appeals decision raises questions on remand instructions for restitution calculations

The Utah Supreme Court convened on April 7, 2025, to discuss the implications of the Court of Appeals' opinion in the case of State v. Blake, #20230435. A significant point of contention during the meeting was the clarity of the appellate court's instructions regarding remand and restitution calculations.

One of the justices raised concerns about the ambiguity in the Court of Appeals' ruling, suggesting that it could have been interpreted in multiple ways. The justice noted that while the appellate court could have simply reversed the decision, it also had the option to remand the case for further hearings. This would have allowed for the introduction of any admissible evidence that could affect the final restitution figure.

The discussion highlighted a common issue in appellate cases: parties often focus solely on the outcome of their appeal—whether it is affirmed or reversed—without considering the necessary steps that should follow a remand. The justice questioned whether the Court of Appeals could have provided clearer instructions for recalculating restitution based on sufficient evidence, but ultimately concluded that, in this specific context, such instructions were not feasible.

This meeting underscores the complexities involved in appellate court decisions and the importance of clear guidance for lower courts on remand procedures. The outcome of this case could have significant implications for how restitution is calculated in future cases, emphasizing the need for precise legal language in appellate rulings.