With no explanation, chose the best option from "A", "B", "C" or "D". 155, 123 Cal.Rptr.2d 622, 627 (2002)). It is a well-established principle in other jurisdictions that a civil settlement releasing a defendant from liability does not foreclose the state from seeking restitution in a criminal case. See State v. Iniguez, 169 Ariz. 533, 821 P.2d 194, 197 (Ct.App.1991) ("[The distinction between civil damages and restitution means that the victim's release of civil liability does not prevent the state from ordering the criminal law remedy of restitution." (emphasis omitted)); People v. Maxich, 971 P.2d 268, 270 (Colo.Ct.App.1998) ("[A] release from liability obtained in a civil settlement cannot limit a criminal court's authority to order restitution equivalent to actual pecuniary damages."); State v. Applegate, 266 Kan. 1072, 976 P.2d 986, 938 (1999) (<HOLDING>); State v. Belfry, 416 N.W.2d 811, 813

A: holding that a settlement agreement is not a court order and therefore a violation of the settlement agreement would not subject a party to contempt
B: holding that the existence of a prior bankruptcy settlement does not preclude a subsequent criminal restitution order
C: holding that the dismissal of a civil action in state court does not preclude a restitution order on the same claim
D: holding that because the state was not a party to a settlement agreement a civil release of claims does not and cannot specifically preclude courtordered restitution in a criminal case
D.