What is the test for determining whether a victim's economic loss is a result of the crime?

Section 1202.4, subdivision (f), limits a victim's restitution award to "economic loss[es incurred] as a result of the defendant's conduct." California courts have applied principles of proximate cause developed in tort to analyze whether victim restitution is a "result" of the crime. (People v. Holmberg (2011) 195 Cal.App.4th 1310, 1321-1322 (Holmberg).) Both in tort and criminal restitution cases dealing with causation issues, "California courts have adopted the 'substantial factor' test in analyzing proximate cause." (Id. at p. 1321.)