Recent Development: In Re Tyrell A.: Trial Courts Generally May Not Order Restitution to an Individual Whose Voluntary Participation in a Crime or Delinquent Act Results in Injury

The Court of Appeals of Maryland held that Sections 11-601(j) and 11- 603(a) of the Maryland Code, Criminal Procedure Article, do not authorize trial courts to order restitution to an individual who suffers an injury while voluntarily participating in a crime or delinquent act, “absent exceptional circumstances.” In re Tyrell A., 442 Md. 354, 383, 112 A.3d 468, 485 (2015). Accordingly, the court of appeals vacated a juvenile court’s restitution order to an individual who suffered nasal injuries while participating in the common law offense of affray.