How have courts dealt with the issue of possession of stolen property and restitution awards?

In Holmberg, the defendant pled guilty to possession of stolen property and was ordered to pay restitution to the owners of the property. The defendant argued that the restitution award was improper because the victim's losses were caused by the burglary and theft of the property and not by his mere possession. (People v. Holmberg, supra, 195 Cal.App.4th at p. 1818.) The reviewing court rejected this argument, noting "there can be more than one cause of injury and that multiple causes can combine to cause harm." (Id. at p. 1322.) The court found it "significant" that the defendant obtained the property the day it was stolen. (Ibid.) Because he did not turn it over to the police, the "[d]efendant's conduct played far more than a negligible or theoretical part in bringing about the victims' injuries and was a substantial factor in causing the harm they suffered." (Ibid.)