State v. Slover
In State v. Slover, 220 Ariz. 239, 204 P.3d 1088, 2009 WL 295027 (Ariz. Ct. App. 2009), the Court reversed a restitution award of attorney fees to a widow after she had hired an attorney who pressured the state to prosecute her husband's murder, actively searched for the defendant in other states, and assisted in the preservation of evidence. Id. PP 7, 9.
The Court determined such tasks "were actually the state's responsibility . . . and not incurred as a direct result of the offenses." Id. P 9.