In re James C.

Summary

The Rhode Island Supreme Court considers whether repair estimates were properly admitted at a juvenile restitution hearing. The court holds that due process applied but the Rhode Island Rules of Evidence did not strictly govern the sentencing-related hearing, and that admitting the estimates as a rational method of calculating restitution did not violate the respondent's rights. The Family Court's restitution order was affirmed.

Holdings

1. A juvenile ordered to pay restitution as a condition of probation is entitled to a hearing to determine the amount of restitution, including an opportunity to be heard and to confront witnesses, because the order implicates property and liberty interests protected by the Fourteenth Amendment.
2. The Rhode Island Rules of Evidence need not be strictly applied at a juvenile restitution hearing because the rules do not apply to sentencing proceedings.
3. The Family Court did not err by admitting the repair estimates and considering Znamirowski's testimony about them in fixing restitution.

Questions Presented

1. Whether admission of two repair estimates at a juvenile restitution hearing violated James C.'s Fourteenth Amendment right to due process.
2. Whether the Rhode Island Rules of Evidence, including objections based on hearsay, authentication, and the best-evidence rule, applied to the restitution hearing.
3. Whether the Family Court properly relied on the repair estimates and related testimony to determine the amount of restitution.

Disposition

affirmed