In delinquency case, unpaid restitution debts do not foreclose a finding of satisfactory completion of probation. In 2011, when J.G. was 17, he committed a residential burglary (Pen. Code, §§ 459, 460, subd. (a)) and was adjudged a ward of the court. He was ordered to pay victim restitution. J.G. satisfactorily completed his court-ordered time at a youth rehabilitation center, complied with the terms of his probation, and had no new convictions. When J.G. was 18 years old, the court ordered his parole “terminated successfully” and continued his wardship. At a review hearing in January 2016, probation asked for termination of warship because, at the age of 22, J.G. was beyond the court’s jurisdiction. Over defense objection, the court ruled that his probation terminated unsatisfactorily because he had not paid victim restitution and the court lacked jurisdiction to convert the order to a civil judgment. J.G. appealed. Held: Reversed. A finding of satisfactory completion of probation is important as it entitles a person to have the petition of warship dismissed and his records sealed (Welf. & Inst. Code, § 786, subd. (a)). An unpaid restitution order, including a restitution fine that can be converted to a civil judgment, shall not be deemed to constitute unsatisfactory completion of supervision or probation (Welf. & Inst. Code, § 786, subd. (c)(2)). The statute arguable applies to all restitution orders, not just orders that can be converted to a civil judgment. The more expansive interpretation was immaterial for this case, however, because the juvenile court had jurisdiction to convert the restitution order to a civil judgment. The order was valid when issued and remained enforceable beyond the period of wardship. On appeal, the parties did not dispute that the order could be converted to a civil judgment. The case was remanded with directions to dismiss the petition, find that J.G. satisfactorily completed probation, and to seal all records pertaining to the petition.

The full opinion is on the court’s website here: http://www.courts.ca.gov/opinions/documents/A147463.PDF