Ingram v. State

The Court of Appeals affirmed the judgment of the Court of Special Appeals concluding that the circuit court was permitted to order Appellant to pay restitution in a theft case without a request from the victim or State, holding that the restitution requirement in Md. Code Ann. Crim. Law 7-104 authorizes a court in a theft case to award restitution, regardless of whether the State or the victim requests that relief.The restitution order in this case stemmed from Appellant’s theft conviction and required him to pay his victim the value of the goods he stole in the amount of $18,964.55. On appeal, Appellant argued that restitution was improper because Md. Code Ann. Crim. Proc. 11-603(b)(1) contains a provision that obliges the victim or State to request restitution in order to trigger a presumed right to receive restitution. The Court of Criminal Appeals affirmed the order of restitution, concluding that the sentencing judge was obliged to order restitution pursuant to section 7-104(g)(1)(i)(2). The Court of Appeals affirmed, holding that section 7-104(g)(1)(i)(2) exists as an exception to section 11-603(b)(1). View "Ingram v. State" on Justia Law