State v. Williams

In State v. Williams, 520 So. 2d 276 (Fla. 1988), the Court interpreted section 775.089(1)(a), Florida Statutes (1985), the predecessor statute to the present statute, which provided that the court "shall order the defendant to make restitution to the victim for damage or loss caused directly or indirectly by the defendant's offense." In Williams, the defendant was convicted of leaving the scene of an accident resulting in personal injury, and the trial court ordered her to pay restitution as a condition of probation. Id. Although agreeing that damages resulted from the accident, Williams argued that no damages were caused, either directly or indirectly, by her offense of leaving the scene of an accident. See id. The State maintained that leaving the scene was just one link in the chain of events in which the injuries took place. See id. Consequently, the State argued that the events consisting of an accident in which people were injured, and Williams' hasty departure, formed a causal chain linking the offense of leaving the scene to the injuries sustained in the accident. See id. In rejecting the State's argument, the Court stated: "The damages arising out of the accident would have occurred with or without Williams committing the offense of leaving the scene of an accident. Those damages transpired independent of that crime. This Court, in J.S.H., allowed restitution in a case where there was a significant relationship between the damages and the offense. This significant relationship test does not replace the causal relationship required by section 775.089(1)(a). Rather, we believe that the significant relationship test enunciated in J.S.H. should work in conjunction with the causation required by the statute." Id. at 277. Because the damages arising from the accident were not caused by the act of leaving the scene of the accident, and therefore bore no relationship to the crime for which the defendant was convicted, the Court approved the lower court decision that struck the restitution award as a condition of probation. See id. at 278.