A sad case: Carjacker carjacks car, causes accident that kills dog in the back seat of the carjacked car. The carjacker gets 12 years. The carjacking victim seeks $15k restitution for the loss of the dog; the district court orders the carjacker to pay $1k. Eighth Circuit (over a dissent): The restitution award should have been based on what it cost to replace the dog, and there’s no evidence that it was as much as $1k. Reversed.