In People v. Birkett (1999) 21 Cal. 4th 226, the defendant pled guilty to automobile theft and owning and operating a "chop shop" to dismantle and sell the parts, and agreed to pay restitution to several victims whose vehicles had been stolen. (Id. at pp. 229-230.) At a hearing on restitution, the trial court found two of the victims had been partially reimbursed under their automobile insurance policies, and ordered restitution to the insurance companies for those amounts. The Supreme Court reviewed the applicable statutory scheme and held that restitution was authorized (even as a condition of probation) only to direct crime victims, and insurance companies do not qualify as such merely by reimbursing crime losses under the terms of policies of insurance. (Id. at pp. 243-247.)