State v. Morris
In State v. Morris, 173 Ariz. 14, 839 P.2d 434 (App. 1992), the Court affirmed an award of restitution for the cost of taxi fares and car rental fees after the victim's vehicle was damaged by the defendant. 173 Ariz. at 18-19, 839 P.2d at 438-39.
The court stated that "basic necessities of everyday life" should be recoverable in criminal restitution. Id. at 19, 839 P.2d at 439.
Although this Court declined to adopt an unduly narrow approach to compensable criminal restitution awards, the approach is nonetheless pragmatic.
Significantly, the court's illustrations of awards for the "necessities of life" involved subsequent expenditures for medical treatment, mental health counseling, and moving to a safer location. Id.
In addition, the restitution awarded for the victim's deprivation of the vehicle did not relate to his inability to use the vehicle or gaze upon its visage, but to the costs associated with replacing how he used the vehicle. Id.