Arizona Court Holds Indian Tribes May Be Beneficiaries of Criminal Restitution Award

Here is the opinion in State v. Leal (Ariz. Ct. App.):

state-v-leal.pdf

An excerpt:

Defendant Carlos Leal appeals a restitution order requiring him to pay $5,500 in funeral expenses for a man he shot and killed in a bar. Leal does not challenge his murder conviction or resulting prison sentence. He does not argue the funeral expenses were unreasonable or unpaid. Instead, because the restitution award went to the Quechan Indian Tribe, rather than to a member of the victim’s family, Leal argues the order was fundamental error. Because Leal has shown no error, the restitution order is affirmed.