Defendant was convicted in the Municipal Court of making a false report to law enforcement, arising out of incident in which defendant falsely reported active shooter situation to city police department.
Defendant appealed convictions and sentence, which included restitution order.
The Court of Appeals affirmed convictions but vacated restitution order. City appealed.
The Supreme Court held that a municipal corporation cannot be a “person” against whom a criminal offense or delinquent act is committed and thus does not qualify as a “victim” which could receive an award of restitution, under constitutional amendment expanding rights of crime victims, or Marsy’s Law.