A trial court is not required to articulate a particular method of calculating noneconomic victim restitution awards. However, appellate review of such awards requires “careful consideration” of multiple factors that include comparison with awards in other cases. Here, neither the $1.8 million ordered to a molestation victim nor the lesser amounts granted to her mother and brother “shock the conscience,” but an award to the victim’s sister was reversed for absence of supporting evidence.

The full opinion is available on the court’s website here: https://www4.courts.ca.gov/opinions/documents/F089345.PDF