What is the test for determining the appropriate amount of restitution under section 1202.4 of the California Criminal Code?

In relevant part, section 1202.4, subdivision (f)(3) provides that the victim restitution award "shall be of a dollar amount that is sufficient to fully reimburse the victim . . . for every determined economic loss incurred as the result of the defendant's criminal conduct, including, but not limited to, all of the following: . . ." In the ensuing subparagraphs, section 1202.4 lists certain categories of loss awards which are specifically authorized. However, because of the "including, but not limited to" language, a trial court may compensate the victim for any economic loss which is proved to be the direct result of the defendant's criminal behavior, even if not specifically enumerated in the statute. (See People v. Mearns (2002) 97 Cal.App.4th 493, 499 (Mearns).)

"The trial `court's allocation of restitutionary responsibility must be sustained unless it constitutes an abuse of discretion or rests upon a demonstrable error of law.'" (People v. Draut (1999) 73 Cal.App.4th 577, 581, quoting In re S.S. (1995) 37 Cal.App.4th 543, 550.) "A trial court abuses its discretion when it determines an award amount using other than `a rational method that could reasonably be said to make the victim whole' or when an award is arbitrary or capricious." (Id. at p. 582, quoting People v. Thygesen (1999) 69 Cal.App.4th 988, 992 (Thygesen).)