California, United States of America
The following excerpt is from People v. Foalima, C071581 (Cal. App. 2015):
Here, of course, defendant's relationship to Shalini's loss arises not only from an arson for which defendant was acquitted, but also from a murder for which he was convicted. Accordingly, the trial court's task was to determine whether the criminal conduct for which defendant was convicted was the proximate cause of the damage to Shalini's clothing and household items. (See People v. Holmberg (2011) 195 Cal.App.4th 1310, 1320-1322; People v. Jones (2010) 187 Cal.App.4th 418, 425 (Jones).)
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