Summary Case

After Timothy Garcia was convicted for unlawful distribution of a con- trolled substance, the state sued him for return of the "buy money" used to buy narcotics from him. The state could compel repayment if there was a valid civil basis for recovery. As the sale of a controlled substance is an ille- gal sale, does the state have a legal basis for recovery? [State v. Garcia,866 P.2d 5 (Ct. App. Utah)]