People v. J.L., et al.

Summary

The California Court of Appeal affirmed juvenile court orders holding four co-offenders jointly and severally liable for $15,850.54 in victim restitution. The court held that substantial evidence supported the portion of the award for childcare expenses incurred by the victim’s mother. It also held that the 2025 amendment to Welfare and Institutions Code section 730.6, eliminating joint and several liability for juvenile victim restitution, applies prospectively only.

Holdings

1. The juvenile court did not abuse its discretion in awarding $3,850 for childcare expenses. The evidence, including the mother's statements and the babysitter's written statement, provided a prima facie showing and substantial evidence of the claimed loss, and the mother was not required to identify every date on which childcare was purchased.
2. The amendment requiring several liability and apportionment of juvenile victim restitution operates prospectively only. It does not retroactively alter restitution orders entered before January 1, 2025.

Questions Presented

1. Whether substantial evidence and a factual and rational basis supported the $3,850 award for childcare expenses.
2. Whether Welfare and Institutions Code section 730.6, subdivision (b)(3), effective January 1, 2025, applied retroactively to eliminate joint and several liability for restitution orders entered before its effective date.

Disposition

affirmed