Jefferson Memorial

On the Victims of Violent Crime Fund (VVCF) in D.C.

Jamison KoehlerDomestic Violence, Opinions/Cases

The Victims of Violent Crime Fund (VVCF) in D.C. provides financial assistance to victims of violent crimes and their families. 

Funded primarily by court-ordered fees collected from people who are convicted of crimes in the District, the VVCF can reimburse people for funeral and burial expenses, medical and mental health care, lost wages and, for domestic violence victims, temporary shelter.

While court-ordered fines are discretionary, assessments under the VVCF are mandatory:  No less than $50 and no more than $250 for misdemeanor and serious traffic offenses and between $100 and $5,000 for felony convictions.

The VCCF fees/assessments are in addition to potential court fines.

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The appellant in Emero Tornero v. United States, __ A.3d. __ (D.C. 2025), challenged the legality of the fees he was assessed after being convicted of a number of criminal offenses. 

Specifically, he argued that the criminal statutes under which he was convicted “did not provide for fines as a punishment.” 

TL;DR version of the Court’s holding:  The amounts of money assessed against the defendant under the Victims of Violent Crime Compensation Act (VVCCA) of 1981 were fees under D.C. Code § 4-516(a), not fines under the criminal statutes. 

Thus, the “trial court did not impose an illegal sentence when it imposed VVCCA assessments on Mr. Tornero for [Assault with a Dangerous Weapon] offenses arising under a statute that did not provide for fines.” 

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Although short and to the point, the opinion briefly discusses a number of rules of statutory interpretation.

For future reference, these include:

–“When interpreting a statute, we begin with its plain language to determine if it is unambiguous.”

–“Our role is to ascertain and give effect to legislative intent and to give legislative words their natural meaning.”

–“This is a holistic endeavor, in which we look not at words in isolation . . . but at their placement and purpose in the statutory scheme.”

–“We may also look to the legislative history to ensure that our interpretation is consistent with legislative intent.”

–“In interpreting a statute, we are bound by the holdings of our prior decisions interpreting the statute.” 

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Then Associate Judge Jennifer Anderson presided at the original trial.  Thomas Burgess represented Mr. Tornero on appeal.