State v. C.G
In State v. C.G., 114 Wn. App. 101, 55 P.3d 1204 (WashCtApp 2002) a high school student who was being arrested threatened the arresting officer several times before kicking and damaging his patrol car as he placed her in the vehicle for transportation to a detention facility.
The student was later convicted of felony harassment for the threats she made to the police officer. As part of her sentence, the court ordered her to pay restitution to the police department for the damage to the patrol car.
On appeal, the student challenged the restitution order arguing that the damage to the patrol car was not causally related to the harassment offense for which she was convicted.
The Washington Court disagreed stating:
"The trial court reasoned that restitution was appropriate because the kicking of the car was part of the same criminal episode as the verbal threats - together, they constituted words or conduct that placed Officer Glover in reasonable fear that the threat would be carried out. This was a tenable basis for concluding the damage to the patrol car was caused by the criminal acts of harassment for which C.G. was convicted." (C.G., 55 P.3d at 1207.)