State v. Debrok

2025 UT 40
CourtUtah Supreme Court
DecidedSeptember 25, 2025
DocketCase No. 20240075
StatusPublished

This text of 2025 UT 40 (State v. Debrok) is published on Counsel Stack Legal Research, covering Utah Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Debrok, 2025 UT 40 (Utah 2025).

Opinion

This opinion is subject to revision before final publication in the Pacific Reporter 2025 UT 40

IN THE

SUPREME COURT OF THE STATE OF UTAH

STATE OF UTAH, Appellee, v. WILLIAM BISSET DEBROK, Appellant.

No. 20240075 Heard May 14, 2025 Filed September 25, 2025

On Certification from the Court of Appeals

Third District Court, Salt Lake County The Honorable Todd M. Shaughnessy No. 231909068

Attorneys: Derek E. Brown, Att’y Gen., Erin Middleton, Asst. Solic. Gen., Salt Lake City, for appellee Nathalie Skibine, Elise Lockwood, Salt Lake City, for appellant

JUSTICE PETERSEN authored the opinion of the Court, in which CHIEF JUSTICE DURRANT, ASSOCIATE CHIEF JUSTICE PEARCE, JUSTICE HAGEN, and JUSTICE POHLMAN joined.

JUSTICE PETERSEN, opinion of the Court: INTRODUCTION ¶1 William Debrok pled guilty to two third-degree felonies for engaging in a recurring scheme in which he and a friend stole merchandise from Walmart. As part of his plea agreement, Debrok admitted that Walmart had incurred over $10,000 in damages as a result of this criminal conduct. When the district court addressed restitution, Debrok asked the court to apportion the damages equally between him and his codefendant based on principles of STATE v. DEBROK Opinion of the Court

comparative fault. In other words, Debrok asserted that because he and his codefendant were equally at fault for Walmart’s losses, the restitution amount should be divided equally between them. But the district court concluded that precedent from the court of appeals prevented it from doing so. The district court had already ordered Debrok’s codefendant to pay the entire amount of damages. And it ordered the same of Debrok, holding both defendants jointly and severally liable for the full restitution amount until it was paid in full. ¶2 The question before us is whether, in a situation like this, a district court can apportion a restitution amount between criminal codefendants based on principles of comparative fault, or whether each defendant must be held jointly and severally liable for the damages the defendant proximately caused. The answer to this question is found in the language of the Crime Victims Restitution Act (Restitution Act or Act), which governs criminal restitution orders. The Restitution Act states that “the court shall order a defendant . . . to pay restitution to all victims . . . for the entire amount of pecuniary damages that are proximately caused to each victim by the criminal conduct of the defendant.” UTAH CODE § 77-38b-205(1)(a)(ii). ¶3 We conclude that this provision of the Act requires each defendant to pay restitution for all of the damages the defendant proximately caused, even if those damages overlap with amounts owed by codefendants. It conflicts with comparative fault apportionment and requires joint and several liability when two or more defendants proximately cause the same damages. Accordingly, we affirm the district court’s restitution order, which makes Debrok and his codefendant jointly and severally liable for the entire amount of damages until the amount is paid in full.1

__________________________________________________________ 1 We emphasize that this does not mean that Walmart will be

repaid twice. The law generally disfavors double recovery. See Hexcel Corp. v. Lab. Comm’n, 2022 UT App 52, ¶ 39, 510 P.3d 310 (“As our supreme court once colorfully pointed out, a plaintiff who prevails against a defendant on a claim of wrongful possession of a cow may not recover both the cow and the reasonable value of the cow.” (cleaned up)). The defendants are jointly and severally liable only until Walmart receives the total amount of damages owed. Joint and several liability simply ensures that the at-fault parties— not the victim—bear the risk of insolvency.

2 Cite as: 2025 UT 40 Opinion of the Court

BACKGROUND ¶4 Debrok and his codefendant were arrested for a scheme to steal property from Walmart. Working together, Debrok or his codefendant would purchase items from Walmart and place them in a car. While one of the men waited in the car, the other would immediately walk back into the store, grab items identical to the ones they had just bought, and leave without paying for them. If stopped by a Walmart employee, they would simply show the receipt from the earlier transaction as “proof” of purchase. After securing the stolen items in the car, either Debrok or his codefendant would return the stolen items to a different Walmart location for cash or gift cards. The pair pulled off this scheme several times. ¶5 But they were eventually caught and arrested. Debrok pled guilty to two counts of unauthorized possession of property, both third-degree felonies. In the plea agreement, Debrok “agreed to pay restitution, splitting the amount with his codefendant.” The parties also agreed that the losses caused by this scheme, and therefore the amount of pecuniary damages owed to Walmart under the Restitution Act, totaled $10,061.32. See UTAH CODE § 77- 38b-102(19)(a) (defining “[p]ecuniary damages” as “all demonstrable economic injury, losses, and expenses”). ¶6 At sentencing, Debrok did not contest the amount of damages or that his participation in the scheme had proximately caused all of the pecuniary damages Walmart had sustained. Rather, he asked that instead of ordering him jointly and severally liable for the full restitution amount, the court split the amount evenly between him and his codefendant according to comparative fault principles. In comparative fault liability, also referred to as comparative negligence, the fact finder allocates the percentage of fault attributable to each defendant and each person seeking recovery, among others, and each defendant is liable for an amount no greater than “the proportion of fault attributed to that defendant.”2 UTAH CODE § 78B-5-818(3), (4). In contrast, joint and several liability renders “each liable party . . . individually responsible for the entire obligation” no matter their level of blameworthiness. Joint and Several Liability, BLACK’S LAW

__________________________________________________________ 2 Comparative negligence may also preclude recovery for a civil

plaintiff if the plaintiff’s fault exceeds the fault of others. See UTAH CODE § 78B-5-818(2). But that is not at issue here.

3 STATE v. DEBROK Opinion of the Court

DICTIONARY (12th ed. 2024). Debrok suggested to the court that his codefendant had been more at fault because he “tended to be the primary actor with a lot of the[] transactions.” But because they had worked together the entire time, Debrok assumed half of the fault and asked that he be required to pay only half of the damages. ¶7 The district court rejected Debrok’s request and ordered that he be held jointly and severally liable for the entire restitution amount along with his codefendant. In its order, the district court reasoned that it was bound to apply State v. McBride, a case in which the court of appeals rejected a criminal defendant’s request to reduce a restitution order according to principles of comparative fault because at the time, comparative negligence was not available in civil actions involving intentional torts. 940 P.2d 539, 545 (Utah Ct. App. 1997), overruled on other grounds by State v. Ogden, 2018 UT 8, 416 P.3d 1132. The district court noted that much of McBride’s reasoning had been undermined by Graves v. North Eastern Services, Inc., a subsequent civil case interpreting the Liability Reform Act (LRA)—which expanded the scope of Utah’s comparative negligence regime—to provide for comparative fault apportionment of intentional tort damages. 2015 UT 28, ¶ 46, 345 P.3d 619. However, the district court concluded it was bound to follow McBride’s holding because the case had not been overturned.

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