In People v. Woods (2008) 161 Cal.App.4th 1045, the court addressed the validity of a victim restitution order where the defendant was convicted of being an accessory after the fact of a murder which occurred during a drive-by shooting. The conviction was based on the defendant's conduct in receiving the gunman's weapon immediately after the murder. The defendant was sentenced to prison and ordered to pay full restitution to the victim's family representing their economic losses resulting from the murder. (Woods, supra, 161 Cal.App.4th at pp. 1048-1049.) On appeal, the defendant argued the victim restitution order was unlawful because he was not convicted of murder but only of being an accessory after the fact, there was no nexus between his criminal act of handling the murder weapon and the family's economic losses, and he was not convicted of being a coconspirator or aider and abettor to the murder. (Id. at p. 1049.) Woods held the victim restitution order was invalid. It noted that a charge of being an accessory after the fact is based on conduct taking place only after the loss was sustained, and that section 1202.4 limited "the scope of victim restitution to the operative crime that resulted in the loss. " (Woods, supra, 161 Cal.App.4th at p. 1052.) The economic loss suffered by the victim's family "occurred because of the murder committed by the gunman. Defendant was not convicted as a coconspirator or as an aider or abettor to the murder itself. Thus his criminal conduct did not cause the loss for which compensation was sought." (Id. at p. 1052.)