People of Michigan v. Victor Manuel Garcia, 331244

Victims contracted defendant Garcia, his sister, and brother‑in‑law to repair a Detroit home for $35,000 paid in advance.
Defendant represented he was a licensed residential builder and showed portfolio photos.
Work ceased soon after payment; victims later discovered none of the workers were licensed.
Defendant admitted receiving $6,300 for his work; victims testified they would not have hired him if they knew he lacked a license.
Jury convicted Garcia of unlicensed residential builder (former MCL 339.601(1)) and acquitted him of certain false‑pretenses charges; trial court ordered $6,300 restitution.
Garcia appealed the restitution order, arguing no causal connection between his unlicensed conduct and the victims’ losses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether restitution must be causally connected to the specific offense for which defendant was convicted	Restitution must compensate losses caused by the defendant’s course of conduct giving rise to the conviction; statute requires causation	Restitution here lacked causal connection to the harm for which jury acquitted him; defendant performed work worth $6,300 and should not repay that	Court: Under McKinley and Corbin, restitution requires a factual and proximate causal link to the convicted offense; Garcia’s misrepresentations and unlicensed work caused the payment, so $6,300 restitution upheld

People v Corbin, 312 Mich. App. 352 (court may award only losses factually and proximately caused by defendant's offense)
People v McKinley, 496 Mich. 410 (restitution requires direct causal relationship between convicted conduct and loss)
People v Armstrong, 305 Mich. App. 230 (abuse of discretion standard for restitution amount)
People v Babcock, 469 Mich. 247 (trial court abuses discretion when outcome falls outside range of principled outcomes)
People v Orweller, 197 Mich. App. 136 (distinguishing civil damages from criminal restitution)
People v Coomer, 245 Mich. App. 206 (clear‑error standard for factual findings at sentencing)
People v Mendez, 225 Mich. App. 381 (standard for clear error review)