United States v. Victor Hackett, 311 F.3d 989 (9th Cir. 2002). · Go Syfert
United States v. Victor Hackett, 311 F.3d 989 (9th Cir. 2002). Cases Citing This Book View Copy Cite
“although there are multi- ple links in this causal chain, the district court did not err by finding that conduct was directly related to the cause of the fire.”
80 citation events (78 in the last 25 years) across 7 distinct courts.
Strongest positive: United States v. Brock-Davis (ca9, 2007-10-02)
Treatment trajectory · 2003 → 2026 · click a year to view as-of
2003 2014 2026
Top citers, strongest first. 34 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) United States v. Brock-Davis (4×) also: Cited as authority (rule), Cited "see"
9th Cir. · 2007 · signal: see · quote attribution · 1 verbatim quote · confidence high
although there are multiple links in this causal chain, the district court did not err by finding that conduct was directly related to the cause of the fire.
examined Cited as authority (verbatim quote) United States v. Davis (4×) also: Cited as authority (rule)
9th Cir. · 2007 · signal: see · quote attribution · 1 verbatim quote · confidence high
although there are multi- ple links in this causal chain, the district court did not err by finding that conduct was directly related to the cause of the fire.
discussed Cited as authority (quoted) Morris v. Nielsen
E.D.N.Y · 2019 · quote attribution · 1 verbatim quote · confidence low
although there are multiple links in the causal chain, the district court did not err by finding that conduct was directly related to the cause of the fire.
cited Cited as authority (rule) United States v. Mulligan
9th Cir. · 2024 · confidence medium
United States v. Hackett, 311 F.3d 989, 991 (9th Cir. 2002).
discussed Cited as authority (rule) United States v. Alison Gendreau
9th Cir. · 2023 · confidence medium
If the restitution order “is within the bounds of the statutory frame-work” the order “is reviewed for an abuse of discretion.” United States v. Hackett, 311 F.3d 989, 991 (9th Cir. 2002) (internal quotation marks omitted).
cited Cited as authority (rule) United States v. Pisanu Sukhtipyaroge
8th Cir. · 2021 · confidence medium
After all, the visa fraud “created the circumstances under which the [sexual abuse] occurred.” United States v. Hackett, 311 F.3d 989, 993 (9th Cir. 2002) (quotation marks omitted).
discussed Cited as authority (rule) United States v. Angelo Efthimiatos
8th Cir. · 2015 · confidence medium
Efthimiatos’s conduct “created the circumstances under which the harm or loss occurred.” United States v. Hackett, 311 F.3d 989, 993 (9th Cir.2002) (citation omitted) (internal quotation marks omitted).
discussed Cited as authority (rule) United States v. Marco Luis
9th Cir. · 2014 · confidence medium
STANDARD OF REVIEW “The legality of an order of restitution is reviewed de novo, and factual findings supporting the order are reviewed for clear error.” United States v. Brock-Davis, 504 F.3d 991, 996 (9th Cir.2007) (citing United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002); United States v. Stoddard, 150 F.3d 1140, 1147 (9th Cir.1998)).
discussed Cited as authority (rule) United States v. Nicholas Gossi
9th Cir. · 2010 · confidence medium
“The courts have such authority under the Victim and Witness Protection Act of 1982 (“VWPA”), providing for discretion- ary awards of restitution after conviction for certain crimes, 18 U.S.C. § 3663 , and under the Mandatory Victims Restitu- tion Act of 1996 (“MVRA”), providing for mandatory restitu- tion for crimes of violence and property offenses, 18 U.S.C. § 3663A.”2 Id. “[T]he starting point for interpreting a statute is the lan- guage of the statute itself.” United States v. Hackett, 311 F.3d 989, 991 (9th Cir. 2002) (quoting Consumer Prod.
discussed Cited as authority (rule) United States v. Gossi
9th Cir. · 2010 · confidence medium
“The courts have such authority under the Victim and Witness Protection Act of 1982 (“VWPA”), providing for discretionary awards of restitution after conviction for certain crimes, 18 U.S.C. § 3663 , and under the Mandatory Victims Restitution Act of 1996 (“MVRA”), providing for mandatory restitution for crimes of violence and property offenses, 18 U.S.C. § 3663A.” 2 Id. “[T]he starting point for interpreting a statute is the language of the statute itself.” United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002) (quoting Consumer Prod.
discussed Cited as authority (rule) United States v. Atlantic States Cast Iron Pipe Co.
D.N.J. · 2009 · confidence medium
Fed. 828 (1992 with pocket part updates). 26 The following collection of citations is limited to cases where statutory victim status was in dispute. 27 *477 Statutory victim status was found to exist, over objection by one or more of the parties, in cases of which the following are a representative collection: In re Stewart, 552 F.3d 1285, 1288-89 (11th Cir.2008) (CVRA mandamus petition; circuit court held that mortgage borrowers were CVRA victims of conspiracy to deprive bank of honest services, where defendants were bank officer and co-conspirator whose offense caused borrowers to pay excess…
cited Cited as authority (rule) United States v. Juvenile Female
9th Cir. · 2008 · confidence medium
United States v. Hackett, 311 F.3d 989, 993 (9th Cir.2002).
discussed Cited as authority (rule) United States v. Stephen M. Farish (2×)
8th Cir. · 2008 · confidence medium
“The main inquiry for causation in restitution cases [is] whether there was an intervening cause, and, if so, whether this intervening cause was directly related to the offense conduct.” United States v. Hackett, 311 F.3d 989, 992 (9th Cir. 2002) (quoting United States v. Meksian, 170 F.3d 1260, 1263 (9th Cir. 1999)).
examined Cited as authority (rule) United States v. Farish (4×)
8th Cir. · 2008 · confidence medium
“The main inquiry for causation in restitution cases [is] whether there was an intervening cause, and, if so, whether this intervening cause was directly related to the offense conduct.” United States v. Hackett, 311 F.3d 989, 992 (9th Cir.2002) (quoting United States v. Meksian, 170 F.3d 1260, 1263 (9th Cir.1999)).
discussed Cited as authority (rule) Oberson v. US DEPT. OF AGRICULTURE, FOREST SERV.
9th Cir. · 2008 · confidence medium
Husain v. Olympic Airways, 316 F.3d 829, 835 (9th Cir.2002) (reviewing mixed questions of law and fact regarding proximate cause); United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002) (reviewing factual findings regarding causation). "[A] party's conduct is a cause-in-fact of an event if the event would not have occurred but for that conduct." Gentry, 962 P.2d at 1209 (internal quotation marks and citation omitted).
discussed Cited as authority (rule) Oberson v. United States Department of Agriculture, Forest Service
9th Cir. · 2008 · confidence medium
Husain v. Olympic Airways, 316 F.3d 829, 835 (9th Cir.2002) (reviewing mixed questions of law and fact regarding proximate cause); United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002) (reviewing factual findings regarding causation). “[A] party’s conduct is a cause-in-fact of an event if the event would not have occurred but for that conduct.” Gentry, 962 P.2d at 1209 (internal quotation marks and citation omitted).
discussed Cited as authority (rule) Orberson v. United States
9th Cir. · 2008 · confidence medium
Husain v. Olympic Airways, 316 F.3d 829, 835 (9th Cir. 2002) (reviewing mixed questions of law and fact regarding proxi- mate cause); United States v. Hackett, 311 F.3d 989, 991 (9th Cir. 2002) (reviewing factual findings regarding causation). [9] “[A] party’s conduct is a cause-in-fact of an event if the event would not have occurred but for that conduct.” Gentry, 962 P.2d at 1209 (internal quotation marks and citation omit- ted).
discussed Cited as authority (rule) United States v. Lopez
9th Cir. · 2007 · confidence medium
Such a construction of § 1324(a)(2) would run contrary to Congress’ intent as expressed in § 3237. [5] Third, our conclusion that an offense under § 1324(a)(2) does not end simply because all the statutory elements are sat- isfied is consistent with the ordinary meaning of the phrase “brings to.” See United States v. Cabaccang, 332 F.3d 622, 626 (9th Cir. 2003) (en banc) (“When Congress has not pro- vided special definitions, we must construe words in a statute ‘according to their ordinary, contemporary, common mean- ing[s].’ ” (quoting United States v. Hackett, 311 F.3d 989, …
discussed Cited as authority (rule) United States v. Angelica Lopez (2×)
9th Cir. · 2007 · confidence medium
Third, our conclusion that an offense under § 1324(a)(2) does not end simply because all the statutory elements are satisfied is consistent with the ordinary meaning of the phrase “brings to.” See United States v. Cabaccang, 332 F.3d 622, 626 (9th Cir.2003) (en banc) (“When Congress has not provided special definitions, we must construe words in a statute ‘according to their ordinary, contemporary, common meaning[s].’ ” (quoting United States v. Hackett, 311 F.3d 989, 992 (9th Cir.2002)) (alteration in original)).
cited Cited as authority (rule) United States v. Zimmerman
9th Cir. · 2006 · confidence medium
The legality of an order of restitution is reviewed de novo.” United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002) (quoting United States v. Stoddard, 150 F.3d 1140, 1147 (9th Cir.1998)).
discussed Cited as authority (rule) Lori Oberson, Legal Guardian for Brian Musselman, an Incapacitated Person Kimberlee Musselman, Individually and as the Natural Mother of Devon Musselman, a Minor, Plaintiffs-Appellees-Cross-Appellants v. United States Department of Agriculture, Forest Service, Defendant-Third-Party Plaintiff-Appellant-Cross-Appellee, and State of Montana, by and Through the Department of Fish, Wildlife and Parks West Yellowstone Chamber of Commerce, Defendants-Third-Party v. Jamie Louis Leinberger Patrick B. Kalahar Tim A. Johnson, Third-Party
3rd Cir. · 2006 · confidence medium
Husain v. Olympic Airways, 316 F.3d 829, 835 (9th Cir.2002) (reviewing mixed questions of law and fact regarding proximate cause); United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002) (reviewing factual findings regarding causation). 51 "[A] party's conduct is a cause-in-fact of an event if the event would not have occurred but for that conduct." Gentry, 962 P.2d at 1209 (internal quotation marks and citation omitted).
discussed Cited as authority (rule) Oberson v. United States Department of Agriculture, Forest Service
9th Cir. · 2006 · confidence medium
Husain v. Olympic Airways, 316 F.3d 829, 835 (9th Cir.2002) (reviewing mixed questions of law and fact regarding proximate cause); United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002) (reviewing factual findings regarding causation). “[A] party’s conduct is a cause-in-fact of an event if the event would not have occurred but for that conduct.” Gentry, 962 P.2d at 1209 (internal quotation marks and citation omitted).
discussed Cited as authority (rule) United States v. Diaz-Guerrero
9th Cir. · 2005 · confidence medium
Absent congressional direction to the contrary, words in statutes are to be construed according to their ordinary, contemporary, common meaningfs].” United States v. Hackett, 311 F.3d 989, 991-92 (9th Cir.2002) (internal citations and quotations omitted).
discussed Cited as authority (rule) United States v. Schurig
9th Cir. · 2005 · confidence medium
See United States v. De La Fuente, 353 F.3d 766, 768, 773 (9th Cir.2003) (where crime was the sending of a threat to injure through the mail, the incidental harm caused when the letter leaked a dangerous looking powder in the post office was a direct and proximate result of the crime); United States v. Hackett, 311 F.3d 989, 992-93 (9th Cir.2002) (where crime was aiding and abetting the manufacture of methamphetamine by purchasing, or stealing, items to be used in the manufacture, the burning down of the house where the manufacturing itself took place was a direct and proximate result of the c…
discussed Cited as authority (rule) United States v. Jacob De La Fuente
9th Cir. · 2003 · confidence medium
United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002) (“The legality of an *772 order of restitution is reviewed de novo.”) (quoting United States v. Stoddard, 150 F.3d 1140, 1147 (9th Cir.1998)); United States v. Sango, 967 F.2d 1332, 1334 (9th Cir.1992) (reviewing de novo victim determination made pursuant to the VWPA).
cited Cited as authority (rule) United States v. Timmy Cliatt
9th Cir. · 2003 · confidence medium
United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002).
examined Cited as authority (rule) United States v. James Cabaccang, United States of America v. Richard T. Cabaccang, United States of America v. Roy Toves Cabaccang (4×)
9th Cir. · 2003 · confidence medium
United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002).
discussed Cited as authority (rule) UNITED STATES of America v. Michael J. ANDREWS (2×)
unknown court · confidence medium
“The courts have such authority under the Victim and Witness Protection Act of 1982 (“VWPA”), providing for discretionary awards of restitution after conviction for certain crimes, 18 U.S.C. § 3663 , and under the Mandatory Victims Restitution Act of 1996 (“MVRA”), providing for mandatory restitution for crimes of violence and property offenses, 18 U.S.C. § 3663A.” 1 Id. “ ‘[T]he starting point for interpreting a statute is the language of the statute itself.’ ” United States v. Hackett, 311 F.3d 989, 991-92 (9th Cir.2002) (quoting Consumer Prod.
cited Cited "see" United States v. Rodolfo Guitierrez, Jr.
9th Cir. · 2011 · signal: see · confidence high
See United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002) (“A restitution order is reviewed for an abuse of discretion, provided that it is within the bounds of the statutory framework.”).
cited Cited "see" In Re Fisher
5th Cir. · 2011 · signal: see · confidence high
See United States v. Hackett, 311 F.3d 989, 992-93 (9th Cir.2002). 12 .
cited Cited "see" United States v. Bussell
9th Cir. · 2007 · signal: see · confidence high
See United States v. Hackett, 311 F.3d 989, 991 (9th Cir.2002). 10 .
discussed Cited "see" USA Vbussell (2×)
9th Cir. · 2007 · signal: see · confidence high
See United States v. Hackett, 311 F.3d 989, 991 (9th Cir. 2002). 10 This amount represents the debts schedule for discharge of $3,057,927.09, less $764,400.00 debt to Provident, which was not dis- charged due to a pending adversary proceeding. 13280 UNITED STATES v. BUSSELL actual losses caused by Letantia’s fraudulent conduct—that is, to compare ‘what actually happened with what would have happened if [she] had acted lawfully.’ ” Id. (third alteration in original) (quoting Feldman, 338 F.3d at 220-21 ).
discussed Cited "see, e.g." United States v. Kennedy
9th Cir. · 2011 · signal: see also · confidence medium
However, we have frequently considered proximate causation in interpreting other statutory restitution schemes, specifically the Victim and Witness Protection Act of 1982 (VWPA), 18 U.S.C. §§ 1512-1515 , 3663-3664, and the Mandatory Victims Restitution Act of 1996 (MVRA), 18 U.S.C. §§ 3663A, 3613A. 15 Because both statutes define a “victim” as “a person directly and proximately harmed as a result of the commission of an offense for which restitution may be ordered,” §§ 3663(a)(2), 3663A(a)(2), we have held that restitution under these statutes may be awarded only for losses for w…
discussed Cited "see, e.g." United States v. Sharp
E.D. Va. · 2006 · signal: see, e.g. · confidence medium
See, e.g., United States v. Hackett, 311 F.3d 989, 992-93 (9th Cir.2002) (defendant who pled guilty to aiding and abetting methamphetamine manufacture could be ordered to pay restitution to an insurance company for property damage caused when a co-defendant started a fire by placing a jar of chemicals used to manufacture methamphetamine on a hotplate); United States v. Spinney, 795 F.2d 1410 (9th Cir.1986) (upholding restitution award where defendant, intending to assault the victim, supplied a weapon to an intoxicated co-conspirator who used it to murder the victim).
Retrieving the full opinion text from the archive…
UNITED STATES of America, Plaintiff-Appellee,
v.
Victor HACKETT, Defendant-Appellant
Jeffry Finer, Finer & Pugsley, Spokane, WA, for the appellant., Joseph H. Harrington, Assistant United States Attorney, Spokane, WA, for the ap-pellee.
Reavley, Kozinski, Fletcher.
Cited by 40 opinions  |  Published
1 passage pin-cited by 1 case
Pinpoint authority: bottom 61%
Citer courts: E.D. New York (1)

OPINION

REAVLEY, Circuit Judge.

DefendanL-Appellant Victor Hackett appeals the district court’s order of restitution for property damage caused by a fire that resulted from the operation of a methamphetamine laboratory. He argues that the district court erred (1) by applying 21 U.S.C. § 853(q)(3) to order restitution for property damage, and (2) by finding that he directly and proximately caused the loss. We affirm.

Background

Victor Hackett pleaded guilty to aiding and abetting the manufacture of methamphetamine in violation of 21 U.S.C. § 841 and 18 U.S.C. § 2. Hackett’s co-defendant Shandy Felch rented a home in Spokane, Washington, in which she, her three children, and co-defendant Brady Olds lived. Felch and Olds manufactured metham[*991] phetamine in the upstairs bedroom of the home. Haekett was a frequent visitor and occasional overnight guest at the residence, and he and Olds purchased or stole items necessary for operation of the clandestine methamphetamine laboratory. The drugs manufactured at the home were consumed by Felch, Olds, and Haekett.

On February 26, 2001, Felch placed a jar of chemicals used to manufacture methamphetamine on a hotplate. The jar exploded and a fire ensued. Although Haekett was not present when the fire started, he had spent the prior evening at the house using methamphetamine. Felch fled the house when the fire began, but she later turned herself in to fire investigators and spoke to agents of the Drug Enforcement Administration.

Haekett and his co-defendants were indicted for endangering human life while illegally manufacturing a controlled substance, in violation of 21 U.S.C. § 858, and conspiracy to do the same, in violation of 21 U.S.C. § 846. Each defendant arrived at a plea agreement with prosecutors. Haekett pleaded guilty to aiding and abetting the manufacture of methamphetamine and was sentenced to 51 months in prison.

As a result of the damage caused by the fire, Farmers Insurance Group paid $47,977.74 to the owner of the house in which the laboratory was located. At sentencing, the district judge ordered that the defendants be jointly and severally liable to Farmers for restitution in this amount.

Discussion

“A restitution order is reviewed for an abuse of discretion, provided that it is within the bounds of the statutory frame-work. Factual findings supporting an order of restitution are reviewed for clear error. The legality of an order of restitution is reviewed de novo.” United States v. Stoddard, 150 F.3d 1140, 1147 (9th Cir.1998) (citations omitted). We thus review the district court’s application of 21 U.S.C. § 853(q)(3) de novo, and we review the district court’s factual conclusions regarding causation for clear error.

Mandatory Restitution for Offenses Involving the Manufacture of Methamphetamine

Haekett first contends the district court erred by failing to consider his ability to pay restitution in violation of the discretionary restitution statute. See 18 U.S.C. § 3663(a)(l)(B)(i)(II) (2002). The district court could not consider Hackett’s ability to pay because 21 U.S.C. § 853(q) mandates restitution for victims of methamphetamine manufacturing offenses:

Restitution for cleanup of clandestine sites

The court, when sentencing a defendant convicted of an offense ... involving the manufacture of amphetamine or methamphetamine, shall ... order restitution to any person injured as a result of the offense as provided in section 3663A of Title 18.

21 U.S.C. § 853(q)(3) (2002). Haekett argues that the statute is inapplicable to him because a “person injured” must be an individual who suffers physical or mental injury, not a person or entity that suffers financial loss. In support of this contention, Haekett notes that the Mandatory Victims Restitution Act, codified as 18 U.S.C. § 3663A and referenced by 21 U.S.C. § 853(q)(3), provides different measures of loss for offenses resulting in bodily injury and offenses resulting in property damage. See 18 U.S.C. § 3663A(b).

We find this argument unpersuasive. “[T]he starting point for interpreting a statute is the language of the statute itself.” Consumer Prod. Safety Comm’n [*992] v. GTE Sylvania, Inc., 447 U.S. 102, 108, 100 S.Ct. 2051, 64 L.Edüd 766 (1980). Absent congressional direction to the contrary, words in statutes are to be construed according to “their ordinary, contemporary, common meaning[s].” Pioneer Inv. Servs. Co. v. Brunswick Assocs. Ltd. P’ship, 507 U.S. 380, 388, 113 S.Ct. 1489, 123 L.Ed.2d 74 (1993) (quoting Perrin v. United States, 444 U.S. 37, 42, 100 S.Ct. 311, 62 L.Ed.2d 199 (1979)). In modern legal usage, “injury” is ordinarily synonymous with damage resulting from the violation of a legal right for which the law provides a remedy. See Black's Law Dictionary 789 (7th ed.1999); see also Clark v. City of Lakewood, 259 F.3d 996, 1006-07 (9th Cir.2001) (interpreting Article Ill’s requirement of an “injury-in-fact” to include loss of business revenue); Berg v. First State Ins. Co., 915 F.2d 460, 464 (9th Cir.1990) (interpreting “injury” as financial loss in the Racketeer Influenced and Corrupt Organizations Act); Roemer v. Comm’r, 716 F.2d 693, 697 (9th Cir.1983) (“The ordinary meaning of a personal injury is not limited to a physical one.”).

For present purposes, the significant language in section 853(q)(3) is “as provided in section 3663A of Title 18.” This direction to section 3663A leads to the interpretation that restitution must be ordered in methamphetamine manufacturing cases to victims of both bodily injury and property loss or damage. See 18 U.S.C. § 3663A(b). Section 3663A directs that both physical injury and financial loss are compensable, although different calculi are required to determine the amount of restitution owed the victim for different types of losses. This interpretation is reinforced by the fact that section 3663A(b) refers to “bodily injury,” while section 853(q)(3) omits the modifier “bodily” and refers simply to “any person injured.” Cf. BFP v. Resolution Trust Corp., 511 U.S. 531, 537, 114 S.Ct. 1757, 128 L.Ed.2d 556 (1994) (“[I]t is generally presumed that Congress acts intentionally and purposely when it includes particular language in one section of a statute but omits it in another.” (internal quotation marks omitted)).

As the district court was required to order Hackett to pay restitution, it was unnecessary for the court to consider Haekett’s present or future ability to pay. Further, while the court properly considered financial capacity when scheduling payments, see United States v. Dubose, 146 F.3d 1141, 1143-44 (9th Cir.1998), Hackett did not object to the schedule of payments or address the argument in his briefs, thereby waiving the issue. See United States v. Alexander, 287 F.3d 811, 817 n. 2 (9th Cir.2002); Fed. R.App. P. 28(a)(9)(A).

Restitution for Losses Directly Related to the Defendant’s Conduct

Hackett also argues that the district court erred by imposing restitution because the loss was not sufficiently related to his offense of conviction. Section 3663A(a)(2) defines a “victim” as “a person directly and proximately harmed” by the offense conduct. 18 U.SU. § 3663A(a)(2). According to Hackett, aiding and abetting the manufacture of methamphetamine was not a direct and proximate cause of the fire, and thus Farmers Insurance is not a victim of his offense.

“[T]he main inquiry for causation in restitution cases [is] whether there was an intervening cause, and, if so, whether this intervening cause was directly related to the offense conduct.” United States v. Meksian, 170 F.3d 1260, 1263 (9th Cir.1999). Thus,

the conduct underlying the offense of conviction must have caused a loss for which a court may order restitution....[*993] [A]ny subsequent action that contributes to the loss, such as an intervening cause must be directly related to the defendant’s conduct. The causal chain may not extend so far, in terms of the facts or the time span, as to become unreasonable.

United States v. Gamma Tech Indus., Inc., 265 F.3d 917, 928 (9th Cir.2001) (citations omitted).

Farmers’s loss was caused by Felch placing the jar of chemicals used to manufacture methamphetamine on the hot plate. The district court found that Hackett had knowledge and understanding of the scope and structure of the enterprise and of the activities of Felch and Olds. Hackett does not dispute that he helped acquire ingredients used in the manufacturing process. It was not unreasonable for the district court to conclude that Hackett’s conduct “created the circumstances under which the harm or loss occurred.” United States v. Spinney, 795 F.2d 1410, 1417 (9th Cir.1986) (upholding an award of restitution where the defendant, intending only to assault the victim, supplied a weapon to an intoxicated co-conspirator who used it to murder the victim). Hackett procured the supplies, which were used in the manufacturing operation, which resulted in the fire. Although there are multiple links in this causal chain, the district court did not err by finding that Hackett’s conduct was directly related to the cause of the fire.

AFFIRMED.