California, United States of America
The following excerpt is from People v. Ouriel, B235094 (Cal. App. 2013):
The court's ruling does not constitute reversible error for lack of sufficient particularity. As noted elsewhere, "determination of the amount of restitution is reversible only if the appellant demonstrates a clear abuse of discretion. [Citation.] No abuse of discretion is shown simply because the order does not reflect the exact amount of the loss, nor must the order reflect the amount of damages recoverable in a civil action. [Citation.] In determining the amount of restitution, all that is required is that the trial court 'use a rational method that could reasonably be said to make the victim whole, and may not make an order which is arbitrary or capricious.' [Citation.] The order must be affirmed if there is a factual and rational basis for the amount. [Citation.]" (People v. Akins, supra, 128 Cal.App.4th at p. 1382.)
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