People v. Stanley
54 Cal. 4th 734
| Cal. | 2012Background
- Defendant Stanley vandalized the victim's 1975 Dodge Adventurer in 2009, damaging a door and denting the vehicle so it could not be opened.
- Victim purchased the truck for $950 about 18 months before the vandalism; repair feasibility was acknowledged by an automotive body shop.
- Plea: Stanley pled no contest to felony vandalism in exchange for 16 months and dismissal of other charges.
- Trial court ordered restitution of $2,812.94, the repair estimate; court stated reductions if repair costs ended up lower.
- Court of Appeal affirmed restitution based on repairing the vehicle, aligning with Dina V. and rejecting the Yanez approach.
- Supreme Court granted review to resolve a conflict between Dina V. and Yanez regarding the measure of restitution under Penal Code §1202.4(f)(3)(A).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Measure of restitution for damaged property | Stanley: should be limited to purchase price plus minor inconvenience | Stanley: restitution should not exceed victim's actual loss or replacement cost depending on the rule | Restoration may be repair cost or replacement cost at court's discretion |
| Scope of court discretion under §1202.4(f)(3)(A) | Court should follow Dina V. rationale for full repair cost | Court should limit to lower of repair or replacement value | Trial court may award actual repair cost if repair is possible; not limited to lesser amount |
| Rejection of Yanez's limitation on restitution | Yanez limit to civil-damages framework conflicts with statute | Yanez should control restitution measure | Disapprove Yanez; Dina V. is consistent with §1202.4(f)(3)(A) |
Key Cases Cited
- People v. Dina V., 151 Cal.App.4th 486 (Cal. Ct. App. 2007) (upheld repair-cost restitution; rejected replacement-only view)
- People v. Yanez, 38 Cal.App.4th 1622 (Cal. Ct. App. 1995) (limits restitution to lesser of replacement or repair costs (disapproved))
- People v. Carbajal, 10 Cal.4th 1114 (Cal. 1995) (restitution need not mirror civil damages)
- People v. Giordano, 42 Cal.4th 644 (Cal. 2007) (statutory interpretation guiding restitution discretion)
- People v. Lyon, 49 Cal.App.4th 1521 (Cal. Ct. App. 1996) (broad construction of victim restitution statute)