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Name: In re J.G.
Case #: S240397
Court: CA Supreme Court
District CalSup
Opinion Date: 02/25/2019

Where minor was granted deferred entry of judgment and successfully completely probation, juvenile court did not err in ordering conversion of unpaid restitution balance to a civil judgment. J.G. admitted allegations in a juvenile delinquency petition that he committed vandalism and trespassed and the juvenile court granted deferred entry of judgment (DEJ). Following hearings to address restitution, the juvenile court set the total amount of restitution at $36,381. The court later found J.G. successfully completed all terms of his probation other than payment of restitution, dismissed the petition, and converted the unpaid balance of restitution to a civil judgment. J.G.…

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Name: In re S.O.
Case #: B281863
Court: CA Court of Appeal
District 2 DCA
Division: 2
Opinion Date: 06/28/2018

When a delinquent minor is placed on probation, the juvenile court may impose restitution for victim losses arising from uncharged conduct to foster rehabilitation. A car was stolen on two occasions, and the minor was driving the car following the second theft, using the keys taken during the first theft. The minor was charged with taking or driving a vehicle (Veh. Code, § 10851), but ended up admitting the allegation in an amended petition that he received stolen property (Pen. Code, § 496). He was placed on probation without being declared a ward (Welf. & Inst. Code, § 725,…

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Name: In re J.G.
Case #: C077056
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 01/24/2017

When a minor is granted deferred entry of judgment (DEJ) and the wardship petition is later dismissed, the juvenile court still has authority to convert unfulfilled restitution order to a civil judgment. J.G., a minor, admitted allegations of felony vandalism and trespass. In lieu of adjudging J.G. a ward of the court, the juvenile court granted DEJ under Welfare and Institution Code section 790, placed J.G. on probation, and set victim restitution as a condition of probation. J.G. eventually satisfied the terms and conditions of his probation, except for the payment of victim restitution. The juvenile court terminated J.G.'s probation,…

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Name: In re J.G.
Case #: A147463
Court: CA Court of Appeal
District 1 DCA
Division: 3
Opinion Date: 09/06/2016

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…

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Name: In re Keith C.
Case #: A141529
Court: CA Court of Appeal
District 1 DCA
Division: 4
Opinion Date: 04/24/2015

Where juvenile court orders a minor to pay restitution, the court has authority to enter an abstract of judgment restating the restitution order upon termination of the wardship after the ward turns 21. In February 2006, Keith admitted an allegation in an amended wardship petition that he received stolen property. The victim of the offense was awarded restitution. Keith defaulted on the restitution and thereafter failed to appear at review hearings. Over defense objection, in March 2014, after Keith was over 21 years old, the court issued a JV-790 Judicial Council Form abstracting the restitution order. The minor appealed, claiming…

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Name: In re J.V.
Case #: A140587
Court: CA Court of Appeal
District 1 DCA
Division: 3
Opinion Date: 11/26/2014

Juvenile court has jurisdiction to order restitution in juvenile case after the minor turns 21 where the restitution was previously ordered and a balance remains unpaid. In 2006, when J.V. was 16 years old, he admitted an allegation in a delinquency petition alleging he drove or took a car without permission (Veh. Code, § 10851, subd. (a)) as reduced to a misdemeanor. He was placed on probation. A few months later, the court ordered $2,357.65 in victim restitution. Several years later, at a dispositional hearing after a sustained probation violation, the probation officer reported J.V. still owed over $2,000 in…

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Name: In re Anthony S.
Case #: A140118
Court: CA Court of Appeal
District 1 DCA
Opinion Date: 07/16/2014

Juvenile court may order minor to pay restitution to injured shooting victim even though evidence showed that treating hospital wrote off bills due to victim's indigence. The minor admitted committing an assault with a firearm in which he and a co-defendant shot and seriously wounded a victim, resulting in hospital bills over $400,000. At a hearing to set restitution, the manager of patient billing testified that the hospital wrote off the debt as uncollectable after determining the victim was indigent. He also testified that the hospital would not be seeking to recover money from the victim. At the time the…

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Name: Luis M. v. Superior Court
Case #: S207314
Court: CA Supreme Court
District CalSup
Opinion Date: 06/19/2014

In delinquency case, restitution awarded to city was unsupported because the city failed to comply with statutory scheme that permits restitution based on a city's average costs to investigate and remediate graffiti. Minor Luis admitted committing felony vandalism in Lancaster City in 2011, as alleged in a Welfare and Institutions Code section 602 petition. He was placed on probation with deferred entry of judgment and ordered to pay over $3,800 in restitution for graffiti cleanup costs. As to restitution, Lancaster crime prevention officer Navarro testified she used a 2006 cost model to establish the annual graffiti abatement cost for the…

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Name: In re Scott H.
Case #: B236743
Court: CA Court of Appeal
District 2 DCA
Division: 1
Opinion Date: 11/14/2013

In light of constitutional mandates, a victim's family members are included within the class of "victims" entitled to restitution under Welfare and Institutions Code section 730.6. Appellant, who was 17 years old when he committed his section 288, subdivision (a) offense, appealed the trial court's order awarding restitution to the victim and his family for mental health counseling. Held: Affirmed. In the first appeal, the court held the victim's family members, as derivative victims, were not entitled to restitution under Welfare and Institutions Code section 730.6. The California Supreme Court granted review and transferred the case back to the Court…

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Name: In re K.C.
Case #: C068161
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 10/10/2013

Although restitution ordered as a condition of informal supervision (Welf. & Inst. Code § 654.2) cannot be converted to a civil judgment under Welfare and Institutions Code section 730.6, minor was estopped from raising the issue on appeal because he agreed that section 730.6 would apply. In exchange for informal supervision under section 654.2, minor agreed that a $4,248.14 restitution order would remain in effect until paid in full pursuant to section 730.6 and would not be discharged upon termination of probation. After minor successfully completed his informal supervision, the section 602 petition was dismissed and, over minor's objection, the…

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