In re J.L.

CourtCalifornia Court of Appeal
DecidedDecember 23, 2025
DocketA171588
StatusPublished

This text of In re J.L. (In re J.L.) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re J.L., (Cal. Ct. App. 2025).

Opinion

Filed 12/23/25 CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION TWO

In re J.L., et al. Persons Coming Under the Juvenile Court Law. THE PEOPLE, Plaintiff and Respondent, A171588 v. (Marin County Super. Ct. J.L. et al., Nos. JJ0000003, JJ0000004) Defendants and Appellants.

In 2024, a juvenile court found four co-offenders jointly and severally liable for victim restitution in the amount of $15,850.54. Two of the minors subject to the victim restitution orders, J.L. and O.V. appeal. Both minors argue there was insufficient evidence to support a small portion of the victim restitution amount intended to compensate the victim’s mother for childcare expenses, although they disagree on the precise amount by which the restitution order should be reduced. J.L. asks for a reduction of $730, and O.V. asks for a reduction of $205. In addition, J.L. and O.V. contend they are entitled to apportionment among the four co-offenders of the restitution amount. Effective January 1, 2025, the Legislature amended Welfare and Institutions Code section 730.6 to eliminate joint and several liability for victim restitution in juvenile delinquency matters. (Welf. & Inst. Code, § 730.6, subd. (b)(3), as amended

1 by Stats. 2024, ch. 805, § 6; see Legis. Counsel’s Dig., Assem. Bill No. 1186 (2023–2024 Reg. Sess.).) J.L. and O.V. claim the newly amended statute operates retroactively, and they therefore seek remand to allow the juvenile court to apportion restitution liability among the four co-offenders based on each offender’s percentage of responsibility pursuant to the current version of section 730.6. We find no error in the amount of victim restitution set by the juvenile court, and we conclude the new statute on victim restitution applies prospectively only. Accordingly, we affirm. FACTUAL AND PROCEDURAL BACKGROUND J.L. (Juvenile Court Case No. JJ0000003) On June 20, 2023, the Marin County District Attorney filed a juvenile wardship petition (Welf. & Inst. Code,1 § 602), alleging J.L. possessed or controlled child pornography (Pen. Code, § 311.11, subd. (a); count 1), a misdemeanor. On October 25, 2023, the juvenile court granted J.L. diversion, placing him on informal supervision pursuant to section 654.2. J.L. successfully completed informal supervision, and on August 14, 2024, the court dismissed the wardship petition. O.V. (Juvenile Court Case No. JJ0000004) On June 20, 2023, a juvenile wardship petition was also filed against O.V. It was alleged that, on or about April 26, 2023, O.V. committed sexual battery upon victim Jane Doe (Pen. Code, § 243.4, subd. (e)(1); count 1), a misdemeanor. On November 1, 2023, O.V. and the district attorney reached an agreement. The petition was amended to allege false imprisonment of Jane

1 Further undesignated statutory references are to the Welfare and

Institutions Code.

2 Doe (Pen. Code, § 236; count 2), a misdemeanor; O.V. admitted the allegations of count 2; and count 1 was dismissed.2 The juvenile court placed O.V. on non-wardship probation for six months. On August 14, 2024, the court ordered the non-wardship supervision terminated successfully. Restitution On March 27, 2024, the probation department filed a victim request for restitution of $15,850.54, consisting of $3,850 for “[b]abysitting and transport services for the two younger children” (i.e., Doe’s younger siblings), $3603 for Doe’s mother’s (Mother’s) lost wages from her employment with one of her employers, $4,740 for Doe’s lost wages from her employment with an employer, and $3,657.54 for Mother’s lost wages from her employment with another employer. Attached to the memo were written statements from Doe’s employer and Mother’s employer regarding their missed work due to Doe’s therapy and Mother’s need “to take care of legal meetings for her daughter.” A letter from Mother’s employer listed 22 dates Mother missed her scheduled shifts and an additional five dates when Mother arrived late or left early “to accommodate meetings” related to her daughter. At a hearing on April 24, 2024, the parties requested a contested hearing on restitution. On June 14, 2024, the district attorney filed points and authorities in support of the victim restitution claim against J.L., O.V., and their two co- offenders, which included a memo documenting Mother’s statements to an advocate in the district attorney’s office. Mother explained she had four

2 Because the facts of the offenses are not relevant to the appeal, we do

not recount them here. It is sufficient to note that J.L., O.V., and two co- offenders (minors with related juvenile court cases, Nos. JJ0000001 and JJ0000002) were involved in an incident with victim Jane Doe.

3 children, two of whom were under 10 years old. After the incident with the four co-offenders, Doe had multiple episodes of mental health crisis that required Mother to stay with Doe. When Doe had a mental health crisis, Mother needed a babysitter to pick up the two younger children from school, look after them, and cook them dinner. Mother reported that she paid the babysitters $60 per child per session ($120), plus $25 for food if she had not left food ready for the children. Mother could not “pinpoint exact dates as she was dealing with a lot during that time.”3 At the contested hearing on June 26, 2024, J.L.’s attorney objected to the claim for childcare expenses, arguing there was “no documentation,” “not even a breakdown as to constituent dates.” O.V.’s attorney stated that seven dates had been identified “with both date and reason for the need for childcare,” but “[t]he other dates are vague, not given at all.” The prosecutor responded that it was understandable Mother could not remember specific dates she needed babysitting because “things were very chaotic at that time,” and the request was “not an inappropriate number” given that it covered a period of at least seven months in 2023.

3 The attached memo documented a two-and-a-half hour long meeting

on May 2, 2024, between the district attorney advocate and Mother regarding the victim restitution claim. Mother could identify a few dates in May through July 2023 on which specific events occurred such as when she accompanied Doe to a law enforcement interview, when she had to stay at home with Doe “due to relentless bullying in school” related to the offenses, when she had to hire a babysitter to go to work because Doe was “not in a good mental space to baby sit her own siblings,” when she took Doe to therapy sessions, and when she attended a court hearing and met with a victim advocate. For other instances, Mother “could not remember specific details,” although she reported needing to be home with Doe during periods in July 2023 and in August 2023; she “was juggling a lot between her 4 children [and Doe’s] mental health crisis . . . [and] was not attentive on what occurred on which date.”

4 After hearing the attorneys’ arguments, the court stated it would “give the People an opportunity to supplement their exhibits and substantiate the requests for the amounts.” On July 25, 2024, the district attorney filed supplemental points and authorities in support of the victim restitution claim against J.L., O.V., and their two co-offenders, which included further statements from Mother regarding restitution. Mother explained that, prior to the incident with minors and their co-offenders, Doe assisted in looking after the two younger children, but after Doe started showing signs of mental health struggles, Mother decided it was not safe for Doe to babysit, and she had to hire babysitters. One of the babysitters Mother hired provided a written statement. The babysitter wrote that she worked for Mother on certain days from May through October 2023. She worked from 8:00 a.m. to 3:30 or 4:00 p.m.

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Bluebook (online)
In re J.L., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-jl-calctapp-2025.