Skip to content
Name: People v. Runyan
Case #: B218863
Court: CA Court of Appeal
District 2 DCA
Division: 8
Opinion Date: 09/24/2010
Subsequent History: review granted 1/12/11 (S188068)
Summary

The estate of a decedent qualifies as a victim under Penal Code section 1202.4, subdivision (f) for purposes of restitution. After appellant was convicted of vehicular manslaughter, he was ordered to pay the decedent’s estate victim restitution. Appellant argued that the estate was not a direct victim for purposes of section 1202.4. The court rejected the argument. The statute specifically allows the immediate surviving family of an actual victim who is deceased to recover economic losses. The statute should not be narrowly construed to lead to absurd results. The estate exists only because of the appellant’s crime, and not merely to indemnify or remediate the effects of a crime. Accordingly, it qualifies as a direct victim.