People v. Henderson, 228 Cal. Rptr. 3d 906

Defendant Marlowe Henderson pleaded no contest (July 2016) to stalking, felony vandalism, and disobeying a domestic relations order involving a mother and daughter.
At sentencing (Sept. 2016) victims sought $17,639.68 in restitution; $5,796.79 of that was for purchase/installation of a monitored home security system (cameras, motion detectors, lights).
Insurance covered $9,642.66 for property/car repairs but paid nothing toward the security system.
The trial court ordered $7,997.02 in restitution, including the $5,796.79 security-system expense, without detailed statutory analysis.
Defendant appealed, arguing restitution for residential security systems is limited to convictions for violent felonies under Penal Code §1202.4(f)(3)(J).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Penal Code §1202.4(f)(3)(J) precludes restitution for residential security systems unless the defendant was convicted of a violent felony	Victim (plaintiff) argued restitution for security system is recoverable as part of economic loss caused by defendant	Henderson argued §1202.4(f)(3)(J) confines recovery for residential security expenses to convictions for violent felonies, so restitution here was unauthorized	Court held §1202.4(f)(3)(J) mandates restitution for security systems when tied to violent felonies but does not preclude discretionary restitution for such systems in non-violent-felony cases; affirmed restitution order

People v. Williams, 184 Cal.App.4th 142 (Cal. Ct. App.) (statutory interpretation of restitution orders reviewed de novo)
People v. Keichler, 129 Cal.App.4th 1039 (Cal. Ct. App.) (enumerated restitution items are examples; courts may award other proven economic losses)
People v. Salas, 9 Cal.App.5th 736 (Cal. Ct. App.) (discussed classification of offense as violent felony for restitution under §1202.4(f)(3)(J))
People v. Valencia, 3 Cal.5th 347 (Cal. 2017) (canon against rendering statutory language superfluous)