Mandatory Restitution • Change of Payee to Victim’s Estate • Failure to Deduct Partial Payments

Commonwealth v. Biauce, PICS Case No. 17-0841 (Pa. Super. May 15, 2017) Gantman, J. (12 pages).

Trial court was authorized to modify restitution order to change payee from victim to victim’s estate because executor/administrator stood in the shoes of the deceased victim with respect to entitlement to benefits, and no statutory provisions provided for extinguishment of restitution benefits upon a victim’s death. Order of the trial court affirmed.

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