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n part ¶13 The Arizona Supreme Court repeatedly has declared that “restitution should be ordered for losses that (1) are economic; (2) would not have been incurred by the victim but for the criminal offense; and (3) were directly caused by the criminal conduct.” E.H., 259 Ariz. at 381-82 ¶ 11 (citations omitted); ¶ 9 (2022) (same); ¶ 7 (2002) (similar).

Reed, 252 Ariz. at 330, ¶ 9 ( ¶ 7 (2002)).

But the loss must also be directly caused by the criminal conduct; “[i]f the loss results from the concurrence of some causal event other than the defendant’s criminal conduct, the loss is indirect and consequential and cannot qualify for restitution.” ¶ 7 (2002).

¶8 To support a restitution order, evidence must show the victim suffered a loss that (1) is economic, (2) is “one that the victim would not have incurred but for the defendant’s criminal offense,” and (3) “directly result[s] from the defendant’s criminal conduct.” ¶ 10 (App. 2003) ( ¶ 7 (2002)).

–29 ¶¶ 1, 6–7 (2002), this Court examined statutes implementing victims’ constitutional guarantee for restitution to decide whether and to what extent a court could order restitution for victims of an unlicensed contractor who performed incomplete and faulty home remodeling work.

¶ 5 (App. 2004) ( ¶ 7 (2002)).

te three requirements for types of loss for which restitution may be ordered: (1) the loss must be economic; (2) the loss would not have occurred but for the defendant’s criminal offense; and (3) “the criminal conduct must directly cause the economic loss” such that the loss did not result from the “concurrence of some causal event other than the defendant’s criminal conduct.” ¶ 7 (2002).

Economic loss does not include losses incurred by the convicted person, damages for pain and suffering, punitive damages or consequential damages.” And as this Court explained in State v. Wilkinson, “the loss must be one that the victim would not have incurred but for the defendant’s criminal offense,” and “the criminal conduct must directly cause the economic loss.” ¶ 7 (2002); see also Town of Gilbert Prosecutor’s Office, 218 Ariz. at 469 ¶ 13 (stating that “[r]estitution .

Accordingly, to be recoverable as restitution: “(1) the loss must be economic, (2) the loss must be one the victim would not have incurred but for the criminal conduct, and (3) the criminal conduct must directly cause the economic loss.” Leal, 248 Ariz. at 4 ¶ 12 ( ¶ 5 (App. 2004)); ¶ 7 (2002)).

To be recoverable as restitution: “(1) the loss must be economic, (2) the loss must be one that the victim would not have incurred but for the criminal conduct, and (3) the criminal conduct must directly cause the economic loss.” ¶ 5 (App. 2004) ( ¶ 7 (2002)).

¶ 9 (App. 2007) ( ¶ 7 (2002)); ¶ 4 (App. 1999) (applying relevant legal principles of adult restitution to analysis of juvenile restitution).

¶42 Our supreme court’s guides our inquiry here.

¶ 20 (App. 2002); ¶ 9 ( ¶ 7 (2002)).

However, the defendant is only liable for expenses that “flow directly from the defendant’s criminal conduct, without the intervention of additional causative factors.” ¶ 7 (2002).

¶19 “Restitution is appropriate for those losses that (1) are economic, (2) would not have occurred but for the juvenile’s delinquent conduct, and (3) are directly caused by the delinquent conduct (e.g. not consequential damages).” Andrew C., 160 P.3d at 689; (stating criteria for restitution payment by adult upon conviction).

Instead, the “primary purposes of restitution” are “reparation to the victim and rehabilitation of the offender.” cf. United States v. Behrman, 235 F.3d 1049, 1054 (7th Cir. 2000) (direct victim restitution appropriately substitutes for civil remedy so crime victims need not file separate civil lawsuits).