We determine this court's stated reasons for the sentence are sufficient. In State v. Mai, 572 N.W.2d 168, 170 (Iowa Ct. App. 1997), we stated: "[t]he nature of the crime committed, age, past record, recommendations in the substance abuse evaluation, your blood-alcohol test result and the recommendations and facts included in the presentence investigation" was sufficient; it was "brief but nonetheless adequate." Mai, 572 N.W.2d at 170.

The Court did not state that harm to the victim had to be an element of the underlying offense. In State v. Mai, 572 N.W.2d 168 (Iowa Ct. App. 1997), the defendant was charged with vehicular homicide and operating while intoxicated (OWI) following an accident that resulted in the death of another person. Mai, 572 N.W.2d at 169.

Restitution is a mandatory part of sentencing in Iowa. State v. Mai, 572 N.W.2d 168, 171 (Iowa Ct. App. 1997). In all criminal cases where there is a guilty verdict "the sentencing court shall order that restitution be made by each offender to the victims of the offender's criminal activities."

Restitution Order. Restitution is a mandatory part of sentencing in Iowa. State v. Mai, 572 N.W.2d 168, 171 (Iowa Ct. App. 1997). Restitution shall be ordered in all criminal cases in which the defendant pleads guilty or is found guilty.

Restitution is a mandatory part of sentencing in Iowa. State v.Mai, 572 N.W.2d 168, 171 (Iowa Ct.App. 1997). In all criminal cases where there is a verdict of guilty "the sentencing court shall order that restitution be made by each offender to the victims of the offender's criminal activities."

Decisions regarding sentencing and restitution issues are also reviewed for errors at law, Iowa R. App. P. 4, and are reversed only for a demonstrated abuse of discretion. See State v. Mai, 572 N.W.2d 168, 170 (Iowa Ct. App. 1997). However, to the extent any such decision has constitutional implications, our review is de novo.

ent on [the defendant's] part”); State v. Lewis, 222 Ariz. 321, 214 P.3d 409, 412–13 (Ct.App.2009) (“[E]ven a ‘victimless' crime may support a restitution award when the criminal conduct directly caused the economic damage. Rather than the elements of the crime, ‘the facts underlying the conviction determine whether there are victims of a specific crime.’ ”) (citation omitted); State v. Wilkinson, 202 Ariz. 27, 39 P.3d 1131, 1133 (2002) (defendant who misrepresented himself as a licensed contractor must pay restitution for the salary he received, because it was a direct result of misrepresenting self, but not for shoddy work, which was an indirect result); State v. Guadagni, 218 Ariz. 1, 178 P.3d 473, 477–79 (Ct.App.2008) (defendant ordered to pay restitution to wives who suffered economic losses as a direct result of bigamy because, although bigamy may occasionally be victimless, “the elements of a crime do not alone determine whether a particular person is entitled to restitution”); State v. Mai, 572 N.W.2d 168, 171 (Iowa Ct.App.1997) (State must prove “by a preponderance of the evidence a causal connection exists between the criminal act and the victim's damages”); State v. McBride, 940 P.2d 539, 543–44 (Utah Ct.App.1997) (applying “modified ‘but for’ test” in rejecting defendant's argument that police negligence was not superseding cause of victim's loss); United States v. Vaknin, 112 F.3d 579, 589 (1st Cir.1997) (“Even if but for causation is acceptable in theory, limitless but for causation is not. Restitution should not lie if the conduct underlying the offense of conviction is too far removed, either factually or temporally, from the loss.”).

"It is a mandatory part of sentencing in Iowa." State v. Mai, 572 N.W.2d 168, 171 (Iowa Ct.App. 1997). Iowa Code section 910.2 (2005) provides: In all criminal cases in which there is a plea of guilty . . . the sentencing court shall order that restitution be made by each offender to the victims . . . and, to the extent that the offender is reasonably able to pay, for crime victim assistance reimbursement.

See State v. Harper, No. 17-0813, 2018 WL 1433073, at *1 (Iowa Ct. App. Mar. 21, 2018) (concluding the court's statement was inadequate when the only reasons given were the "nature of the offense" and "prior record"); Cooper, 403 N.W.2d at 802 (finding insufficient "[t]he Court has reviewed the circumstances of the offense, and the defendant's prior background" (alteration in original)). Reasoning we uphold tends to at least state some specific factors, even if it does not elaborate on them or explain how they affect the sentence. See State v. Mai, 572 N.W.2d 168, 170 (Iowa Ct. App. 1997) (finding sufficient "[t]he nature of the crime committed, age, past record, recommendations in the substance abuse evaluation, your blood-alcohol test result and the recommendations and facts included in the presentence investigation"); see also State v. Adams, No. 21-1756, 2022 WL 3907749, at *1 (Iowa Ct. App. Aug. 31, 2022) (finding sufficient "[t]he Court considers the age of the defendant, the criminal history, the impact a consecutive sentence would have on employment and also the family situation, and also the Court considers the need for deterrence, rehabilitation, the nature of the charges and the defendant's criminal history").

But "[b]ecause restitution issues implicate the sentencing court's discretion, a defendant is entitled to have it exercised." State v. Mai, 572 N.W.2d 168, 171 (Iowa Ct. App. 1997). Not so fast, says the State.