California, United States of America
The following excerpt is from People v. Francis, A144176 (Cal. App. 2016):
4. By way of contrast, where separate burglaries of different residences with different victims were involved, People v. Scroggins (1987) 191 Cal.App.3d 502, 504-506 (Scroggins) held a defendant, convicted of receiving stolen property in one crime, could not be required to pay restitution for losses sustained in three other burglaries from other apartments in the same complex, as to which he was never charged or convicted.
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