Abuse of Discretion

The Court of Appeal held that the trial court abused its discretion in ordering noneconomic victim restitution without stating its method of calculation or the factual basis for its order. Such statements are required because they are frequently essential to meaningful review, act as an inherent guard against careless decisions, and aid in preserving public confidence in the decision-making process. The matter was remanded for further restitution proceedings with directions for the trial court to ensure that the record is sufficient to permit meaningful review when it issues its future order. The Court of Appeal noted that the trial court may receive additional evidence and reconsider the noneconomic restitution amount.