California, United States of America
The following excerpt is from People v. E.R. (In re E.R.), E072794 (Cal. App. 2020):
In this case, the grandmother visited the victim to comfort her after the minor's sexual assault on the victim. The People claim that "[a] court may properly order restitution for mental health counseling expenses. (Penal Code 1202.4, subd. (f)(3)(C).) For example, in People v. O'Neal (2004) 122 Cal.App.4th 817, 821, the court found the defendant's restitution payment for the victim's brother's psychological counseling proper. There, the victim was sexually molested as a child. [Citation.] The court classified his brother as a victim as well, and concluded that the trial court may properly order the defendant to pay restitution to the agency that provided counseling to the brother. [Citation.]" The People thereafter stated that, here, "the victim's grandmother flew out in order to support the victim emotionally. After [minor] sexually assaulted her, the victim needed continued emotional support from her family because in the aftermath of the assault and during the pendency of the juvenile proceedings, [minor's] friends harassed the victim on social media."
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