People v. Runyan
Annotate this CaseDefendant, driving while intoxicated, killed another driver instantly in a freeway collision. The accident left no surviving family, dependents, or heirs. Defendant was convicted and sentenced to prison. In addition, pursuant to the statute requiring that persons convicted of felonies pay restitution to the crimes' victims for their resulting economic loss, Defendant was also ordered to pay substantial restitutionary amounts to Decedent's estate. The award represented death-related loss in value of the decedent's business and property, and probate, estate administration, and funeral expenses. The court of appeal affirmed the award. The Supreme Court reversed, holding (1) mandatory restitution is not payable to the estate for economic loss the estate itself has sustained as a result of the death, but the decedent's personal representative is entitled to collect mandatory restitution on the decedent's behalf for economic loss the decedent personally incurred before death as an actual victim of the defendant's criminal conduct; (2) after the actual victim has died, he or she does not incur personal economic loss subject to mandatory restitution; and (3) there was no valid basis for any of the mandatory restitution amounts awarded to the estate in this case.
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