In People v. Martinez, the Supreme Court today holds a superior court erred in awarding restitution to a crime victim for injuries sustained in an accident involving a defendant who was convicted and sentenced not for any crime involving the causing of the accident, but only for leaving the scene of the accident. The court’s unanimous opinion by Justice Leondra Kruger interprets a statute as providing that the trial court could “order restitution for those injuries that were caused or exacerbated by defendant’s criminal flight from the scene of the accident, but it was not authorized to award restitution for injuries resulting from the accident itself.” The court distinguished this limitation from the power of courts to order broader restitution — not directly connected to criminal conduct — as a condition of probation.
The court affirms the Fourth District, Division Two, Court of Appeal. It disapproves a 2006 opinion of the Fourth District, Division One.