The California Supreme Court Reverses Juvenile Graffiti Cleanup Restitution Order Based on “Cost Model” in Luis M.: Big Win for PJDC’s Rourke Stacy

In In re Luis M., S207314, the City of Lancaster averaged costs of graffiti cleanup to determine the child’s restitution award. In a unanimous opinion on June 19, 2014, California’s highest court rejected this approach, reaffirming the long standing principal that restitution under Welfare and Institutions Code section 730.6 “must have some factual nexus …