What is the test for reasonable attorney's fees and other costs of collection?

California, United States of America


The following excerpt is from People v. Cubbage, H041393 (Cal. App. 2016):

Actual and reasonable attorney's fees and other costs of collection . . . . ." (Former 1202.4, subd. (f)(3)(A), (E), (G), (H).)6 "[T]he right to restitution, and the categories of covered 'victims' are to be broadly and liberally construed." (People v. Runyan (2012) 54 Cal.4th 849, 865.) " '[S]entencing judges are given virtually unlimited discretion as to the kind of information that they can consider and the source from whence it comes.' [Citation.] Probation reports are among the permissible sentencing data the court may consider." (People v. Baumann (1985) 176 Cal.App.3d 67, 81.)

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