People v. Santori, 243 Cal. App. 4th 122

Defendant Anthony R. Santori (moniker “Seor”) had prior vandalism and burglary history and admitted responsibility for 36 incidents of graffiti in the City of Palmdale.
Deputies found graffiti images with the moniker on defendant’s phone; the City had photographs of abated graffiti and used them in its investigation.
Santori pled no contest/guilty to counts in two cases and agreed to restitution; the People sought $21,952, the court awarded $18,878.23 after a hearing.
Ruth Oschmann, the City’s crime prevention officer, testified about abatement costs, using a per-minute cost model (100 minutes per incident average) based on cleanup crew, admin costs, salary, deputy time, and Graffiti Tracker software.
Oschmann reviewed the photographs of the graffiti attributed to Santori but did not have exact hours or travel distances for each specific incident; the trial court reduced investigative costs by half before entering restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the restitution award had a sufficient factual nexus to defendant’s specific acts of graffiti	The People argued the City presented evidence linking defendant to photographed graffiti and Oschmann provided a cost estimate (100 minutes per incident) based on those photos	Santori argued, relying on Luis M., that the People used only an average cleanup cost and failed to tie costs to his specific conduct	Court held evidence was sufficient: Oschmann considered the photos and offered a reasonable per-incident estimate tied to defendant’s graffiti, meeting the People’s prima facie burden
Whether the trial court abused discretion by reducing investigative costs	The People sought investigative costs (Graffiti Tracker, deputy) as part of abatement; argued these were legitimate components of economic loss	Santori argued the reduction was a speculative “guesstimate” and not rationally related to his conduct	Court held the court’s reduction was reasonable given defendant’s admissions and limited investigation needed; no abuse of discretion

Luis M. v. Superior Court, 59 Cal.4th 300 (explains restitution for graffiti must have factual nexus to defendant’s conduct and that average citywide costs alone may be insufficient)
People v. Giordano, 42 Cal.4th 644 (standard of review for restitution and presumption of correctness for trial court orders)
People v. Millard, 175 Cal.App.4th 7 (victim restitution limited to economic losses; burden shifts to defendant after prima facie showing)
People v. Birkett, 21 Cal.4th 226 (statutory comparability note cited regarding restitution statutes)