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Name: People v. Leon
Case #: D043917
Court: CA Court of Appeal
District 4 DCA
Division: 1
Opinion Date: 12/01/2004

A court may not impose restitution for economic loss caused by a codefendant unless the defendant aided and abetted those specific crimes. The defendant was convicted of grand theft and passing a forged check, and his codefendant was convicted of three separate counts of passing forged checks and three counts of grand theft. The court ordered the defendant to pay $13,450 in victim restitution, jointly and severally with the codefendant, although the probation report had recommended that the defendant only be ordered to pay $2,450 for his part in the offenses. The Court of Appeal modified the order to reflect the lesser amount, noting that Penal Code section 1202.4, subdivision (f), requires restitution only for economic loss that is a result of the defendant’s conduct.