Several years ago, police investigators in California found a number of stolen vehicles, including some that were being dismantled, on Julio Valdes’ property. He later pleaded no contest to owning and operating a chop shop and was sentenced to two years and four months in prison. The trial court then set a victim restitution hearing.

Prosecutors asked the court to order restitution in the amount of $14,441.01 payable to a collection agency as the representative of Farmers Insurance. The amount was based on a claim of $12,307.26 plus a deductible of $500 and the net salvage value of $1,633.75. After the trial court awarded the full amount to Farmers, the defendant appealed, arguing that the order had to be reversed because there was no evidence that the insurance company was a direct victim of the defendant’s crimes.