What is the test for making restitution as a condition of probation?

In People v. Foster (1993) 14 Cal.App.4th 939, 18 Cal.Rptr.2d 1, this district faced the question of ordering restitution to an insurance company as a condition of probation. The court said:

"Section 1203 et seq. grants trial courts 'broad discretion in the sentencing process, including the determination as to whether probation is appropriate and, if so, the conditions thereof.' (People v. Lent (1975) 15 Cal.3d 481, 486 [124 Cal.Rptr. 905, 541 P.2d 545].) Under section 1203.1, a trial court may impose 'any or all [reasonable probation conditions] as it may determine are fitting and proper to the end that justice may be done, that amends may be made to society for the breach of law, for any injury done to [27 Cal.App.4th 58] any person resulting from that breach, and generally and specifically for the reformation and rehabilitation of the probationer, ...'

"A condition of probation may not be invalidated on appeal unless the condition '(1) has no relationship to the crime of which the offender [was] convicted, (2) relates to conduct which is not in itself criminal, and (3) requires or forbids conduct which is not reasonably related to future criminality....' (People v. Dominguez (1967) 256 Cal.App.2d 623, 627 [64 Cal.Rptr. 290].)

"When restitution is imposed as a condition of probation under section 1203 et seq., rehabilitation of the criminal is the primary goal of restitution. (People v. Richards (1976) 17 Cal.3d 614, 620 [131 Cal.Rptr. 537, 552 P.2d 97].) 'Implicit in the concept of rehabilitation is the need to first deter criminal activity. Courts have generally found an order requiring the defendant to compensate the victim to be a deterrent to future criminal activity. [Citations.]' ( [People v.] Goulart, supra, 224 Cal.App.3d at p. 78, fn. 4 [273 Cal.Rptr. 477].)" (Id. at p. 950, 18 Cal.Rptr.2d 1, italics added.)