People v. Brigner
In People v. Brigner, 978 P.2d 163 (Colo. App. 1999), the defendant sold dairy cows in which the victim held a security interest after the cows had become ill and no longer produced milk.
The trial court ordered restitution based on the value of the dairy cows as producing animals and not their fair market value at the time of the sale.
The Court reversed, holding that the victim was entitled to restitution only for losses suffered as a direct result of the defendant's criminal behavior, and that was the value of the animals at the time of sale.