P. v. Villarreal
Defendant and appellant David Angelo Villarreal appeals after he pleaded guilty to theft. As part of his sentence, defendant was ordered to pay $1,500 in restitution to compensate the victim for moving expenses. Defendant contends that this restitution order was improper. He argues that the victim was caused to move by (1) crimes committed by other persons, and/or by (2) criminal conduct of which he was not convicted. Thus, he argues, the criminal conduct of which he was convicted was not related to or did not cause the victim to incur the expense, and the restitution order was therefore improper. We disagree. Whether or not other actors may also have committed crimes that may have contributed to the victim's decision to move, and even if defendant was not charged with or convicted of other crimes (e.g., criminal threats) that contributed to her decision to move, the criminal conduct that he did commit had a sufficient causal nexus to the victim's economic loss to support the restitution order. The context of his crime was a series of threats to the victim that she must move or her house would be burned down. In that context, defendant's criminal conduct--theft of a blowtorch--was responsible for the victim's loss. We affirm.
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