Court of Appeal (Cal.) Says that Song-Beverly Restitution Does Not Include Registration Renewal Fees

Although the list is nonexhaustive, the examples give guidance as to what constitutes an “incidental damage.” The common characteristic among them is each would be a cost incurred as a result of a vehicle being defective. Such is not the case with vehicle registration renewal fees, which are more accurately characterized as a standard cost of owning any vehicle. Were we to adopt plaintiff’s interpretation, it would open up a “Pandora’s box” of potential costs for which a defendant would need to pay restitution in these types of cases (e.g., costs for gas, car washes, oil changes). Plaintiff provides no authority for such an expansive interpretation.  In sum, the trial court properly concluded the restitution payable under section 1793.2 does not include vehicle registration renewal fees, as opposed to vehicle registration fees associated with the purchase of a vehicle.