People v. Martin

Defendant pleaded guilty to violating the Timber Buyers Licensing Act and was ordered to pay restitution to the victim. Defendant failed to comply with the payment order and the victim filed a motion to hold the defendant in contempt, which the trial court struck on the basis that he lacked standing to initiate contempt proceedings in the criminal case. The victim appealed and the appellate court reversed, explaining that there is no reason why only the State, and not the victim, could pursue contempt actions in a criminal case where restitution is ordered and that this conclusion was supported by the language of the Restitution Statute. (KNECHT and DeARMOND, concurring)