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Commonwealth v. Gregory Ricky Brown J-49-2009 (10/20/2009)

Topic: Restitution – Payment to a Government

Summary: Under 18 Pa.C.S.A. § 1106 Medicare may be a recipient of restitution.

Facts: Gregory Brown was convicted of Simple Assault (18 Pa.C.S.A. § 2701(a)(1)) for beating a victim.  Medicare paid for a portion of the hospital treatment the victim received.  Brown argued that Medicare, as an extension of the federal government, cannot receive restitution.  The Pennsylvania Supreme Court concluded that Medicare is a government agency eligible to receive restitution under 18 Pa.C.S.A. § 1106 if it reimburses a victim for expenses related to the defendant’s criminal conduct.


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