In this case, fraud is far worse than theft. She defrauded investors of hundreds of millions of dollars and spent them on a what was essentially a vanity project. She destroyed hundreds of millions of dollars of private property.

Destroying 100 million is best compared to something like a "killdozer"[0] rampage. Holmes' crime was the destructive equivalent of leveling ~300 homes.

[0]https://en.wikipedia.org/wiki/Marvin_Heemeyer#The_'Killdozer...