California, United States of America
The following excerpt is from People v. Murphy, 2d Crim. No. B270874 (Cal. App. 2017):
Moreover, subdivision (f)(3) of section 1202.4 merely contains a nonexclusive list of losses that must be included in an order of victim restitution. In other words, that a court shall order reimbursement of security expenses for a victim of a burglary that qualifies as a violent felony does not mean that a court shall not order reimbursement of such expenses for a victim of a burglary that does not so qualify. "Because the statute [section 1202.4] uses the language 'including, but not limited to' these enumerated losses, a trial court may compensate a victim for any economic loss which is proved to be the direct result of the defendant's criminal behavior, even if not specifically enumerated in the statute. [Citation.]" (People v. Keichler (2005) 129 Cal.App.4th 1039, 1046.)
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