California, United States of America
The following excerpt is from People v. Huffines, G049350 (Cal. App. 2014):
The People contend that because restitution awards include, but are not limited to, the categories listed in the statute, a vehicle security system is so closely analogous to a residential security system that it should be permitted. The People note that "'"the word 'loss'"'" in section 1202.4 is to "'"be construed broadly and liberally."'" (People v. Crisler (2008) 165 Cal.App.4th 1503, 1508.) The People observe that the victim testified that he is now regularly worried about his vehicle being broken into and contend, "To make this victim whole, it was reasonable for the court to reimburse him for the steps he took to reduce the stress appellant caused."
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