Dec. 6, 2022 – People v. Baudoin (2nd Dist., Div. 1, B317130)

PC 1202.4(f)(3)(I) authorizes victim restitution for “[e]xpenses incurred by an adult victim in relocating away from the defendant [where] verified by law enforcement to be necessary for the personal safety of the victim or by a mental health treatment provider to be necessary for the emotional well-being of the victim.” The Court of Appeal holds the trial court erred by ordering relocation expenses under PC 1202.4(f)(3)(I) without requiring the necessary verification. The court remands for a new victim restitution hearing, “including affording the People an opportunity to provide the necessary verification.”