Commonwealth v. Figueroa, 691 A.2d 487 (Pa. Super. Ct. 1997)

Cases | Commonwealth v. Figueroa, 691 A.2d 487 (Pa. Super. Ct. 1997) | 2018

The three defendants were inmates at the State Correctional Institution of Somerset (SCI/Somerset), when they were involved in an altercation with a fourth inmate, who died as the result of blunt force trauma to the head. After two of the defendants pled guilty to involuntary manslaughter, and the third pled guilty to solicitation to commit assault, the three defendants were sentenced to pay restitution jointly and severally to the SCI/Somerset in the amount of $51,314.83 for medical and hospital expenses arising out of the treatment of the victim. The defendants appealed, arguing that the Department of Corrections (Department) was not a victim as defined by 18 Pa.C.S. §1106(h). On appeal, the court reversed the trial court’s decision, finding that the Department is not a victim under § 1106. The court noted that the 1995 amendments to § 1106 expanded the term victim to include the Crime Victim Compensation Fund and any insurance company that compensated a victim for loss under any insurance contract, because those entities make direct payments to crime victims that such victims could have received as restitution from the perpetrators of crimes. However, to extend the definition of “victim” to the Department in this case would result in the unintentional creation of a system of reimbursement for the costs of the treatment and care of crime victims, regardless of who receives the ultimate benefit.