People v. Superior Court

California Court of Appeal Jun 16, 2011 No. No. D058725Published

Before: McIntyre

AI Brief

AI-generated · verify before citing

Holding. The juvenile court lacked the legal authority to order the district attorney to negotiate medical bill discounts for a victim or to rescind a valid restitution order based on the Hospital Fair Pricing Act. The court must order full restitution for economic losses when the victim has made a prima facie showing of those losses.

Issues

Whether the juvenile court had the authority to order the district attorney to negotiate medical bill discounts on behalf of a victim.
Whether the Hospital Fair Pricing Act requires a victim to seek discounts on medical bills before receiving full restitution.
Whether the juvenile court erred in rescinding a prior restitution order that was based on documented economic losses.

Disposition. writ of mandate issued

Quotations verified verbatim against the opinion

“the juvenile court acted beyond the scope of its authority in rescinding an order of victim restitution and instead ordering the district attorney’s office to negotiate with the hospital to discount the victim’s medical bills.”

“We find nothing in the Hospital Fair Pricing Act that requires a patient to seek a discount for his or her medical bills or suggests that the court has authority to mandate that the patient or the district attorney do so.”

“When a minor causes economic loss to a victim, the trial court must order the minor to make restitution to the victim.”

Opinion

McINTYRE, J. In this case we conclude that the juvenile court acted beyond the scope of its authority in rescinding an order of victim restitution and instead ordering the district attorney’s office to negotiate with the hospital to discount the victim’s medical bills. We, therefore, grant the People’s petition.

FACTUAL AND PROCEDURAL BACKGROUND

In November 2009, Lauren M. punched Kristin Feigel numerous times and caused injury. The juvenile court found true that Lauren committed battery on Feigel and placed her on probation. The court also ordered Lauren to pay $6,660.27 in restitution to Feigel for her medical bills.

[1224]In November 2010, Lauren moved to modify the restitution order arguing that she is in a difficult financial situation, and Feigel should be required to mitigate her damages by negotiating a discount with the hospital. At the restitution hearing, Lauren did not present any evidence. Rather, her counsel argued that the district attorney’s office should be required to assist Feigel with negotiating a discount. The juvenile court denied Lauren’s motion, stating that it did not have the authority to order the district attorney’s office to negotiate with the hospital. Thus, the court confirmed its prior restitution order.

That same day, the juvenile court rescinded its restitution order without explanation and set another hearing on the matter. At the subsequent restitution hearing, the court stated that it reconsidered its prior decision and determined that it was in the best interest of the victim to negotiate the medical bills. The court further indicated that the district attorney’s office should facilitate those negotiations. Accordingly, the court issued an order stating that it would set the restitution amount after “appropriate negotiations” pursuant to Health and Safety Code section 127400 et seq. (Hospital Fair Pricing Act).

This petition followed. We requested a response and stayed proceedings pending further order of this court. Lauren filed a response as the real party in interest.

DISCUSSION

A. Standard of Review

People v. Superior Court

AI Brief

FACTUAL AND PROCEDURAL BACKGROUND

DISCUSSION

More from California Court of Appeal

Related research

DISPOSITION

AI Brief