ability to pay and even though she made less than one hundredth of one per- cent of the profits. Although a defense attorney may represent clients in “white collar” cases, that does not mean the clients have endless amounts of money and assets. They may have made a pittance compared to the windfall of other co-con- spirators. Moreover, they are often left penniless after fighting a federal indict- ment. In spite of those facts, if the client takes a plea or is found guilty, she will still have a restitution obligation. In question and answer format, this article will lay out the law and some opportunities of mit- igating the heavy load of restitution.
Q. What is the applicable law regarding restitu- tion? A. Title 18 U.S.C. § 3663A mandates restitution to victims in nearly all white collar cases. It provides that “the court shall order … that the defendant make
© Gbphotostock | Dreamstime restitution” for any offense against Property under Title 18.2 This includes crimes of racketeer- Restitution in Federal ing, telemarketing fraud, mail and wire fraud, health care fraud, bank fraud, and securities fraud. White Collar Cases: The general conspiracy statute within Title 18 can also draw a non-Title 18 offense within the Squeezing Blood mandatory requirements of § 3663A.3 Under the statute, a victim is a person or entity that is From a Stone “directly and proximately harmed as a result of the commission” of the offense.4 Section 3664 and Fed. R. Crim. P. 32(c) address he purpose of restitution is to make a victim whole the procedure regarding restitution. They direct the after suffering a loss from the criminal activity com- government, at least 60 days prior to sentencing, to Tmitted by others.1 Making a victim whole, however, consult with all identified victims to obtain a restitu- does not always equate to fairness. Consider the nominee tion amount and to provide that information to the owner of a medical clinic who allowed someone to use probation officer.5 The probation officer then must her name in exchange for a few hundred dollars, while provide notice to the victims of the offense of convic- others fraudulently billed Medicare for millions of dollars tion, the amount of restitution, the date of the sentenc- from the clinic in her name. Although the client may not ing hearing, and the availability of a lien. The officer have known all the details of the plan, the scope of the also must inform victims of the chance to submit addi- fraud or the names of the other conspirators, she never- tional loss information through a provided affidavit.6 theless may be found guilty of a conspiracy to commit The client must submit a completed affidavit to Medicare fraud. She may be slapped with a joint and sev- the probation officer containing her detailed financial eral $25 million restitution order even though she has no information, including assets “owned or controlled by
BY A. MARGOT MOSS
20 WWW.NACDL.ORG THE CHAMPION the defendant as of the date” of the projected earnings, and debts — “[a] Q. If the victim receives compensation defendant’s arrest. 7 After finishing its restitution order may direct the from a third party, such as insur - restitution investigation, probation defendant to make a single, lump- ance, does that offset the amount of must submit a report to inform the sum payment, partial payments at restitution? court sufficiently to issue an order. specified intervals, in-kind payments, A. No. If a victim receives reimburse - The report (either as part of the PSI or [] a combination of payments at ment from another source, the court a separate document) must include specified intervals and in-kind pay - will order the defendant to repay that an accounting of what is owed to each ments,” or nominal periodic pay - third party after the victim has been victim, any agreement to restitution, ments. 17 If the court permits a pay - made whole. 29 It may reduce the and the financial circumstances of the ment plan, the installments will be in amount the client pays directly to the defendant. 8 The court may rely on the equal monthly payments, unless the victim, but not the total amount of report or may take additional evi - court directs otherwise. 18 restitution. The reduced amount due dence, resolving any dispute by a pre - The client’s financial disclosure to the victim, added with the money ponderance of the evidence. 9 The does not end at the sentencing stage. that must be paid later to another burden of establishing the restitution Even after an order has been issued, source, will equal the full restitution 10 30
amount is on the government. if there is any material change to the amount imposed. R
After reaching a conclusion client’s finances, she must notify the E
regarding restitution, the court issues court and the U.S. Attorney’s Office, Q. Can the restitution amount be off - S an order. The court’s final order or and the victim must also be set by the value of any forfeited T 19 I judgment must include the client’s informed. Upon notification to all property? T
identifying information, case num - the parties of a change in finances A. In Mandatory Victims Restitution U
ber, restitution amount, schedule of or assets, the court may revise the Act (MVRA) cases, federal law T I
payments, any modification or restitution payment schedule or requires a district court to impose O remission, a requirement that the demand payment in full. 20 both restitution and forfeiture. 31 N client keep her address current with Because restitution and forfeiture
the U.S. Attorney’s Office, and iden - Q. Can the client transfer title to serve very distinct purposes and are I tification of the victims. 11 The U.S. property to a third party to decrease both required by statute, a court can - N
Attorney’s Office (USAO) then must her assets? not offset the amount of restitution F
file a lien against the client’s proper - A. A sincere sale or donation of proper - by the amount of property or monies E ty. 12 A Release of Lien is not filed ty to another is permissible. But forfeited to the government. 32 Thus, a D until the restitution has been paid. 13 keep in mind that, in preparation for client may be doubly penalized finan - E the restitution order, the client is cially. “While restitution seeks to R A Q. Is there any circumstance in which the mandated to provide sworn infor - make victims whole by reimbursing L
court would not order restitution in mation to the probation officer them for their losses, forfeiture is white collar cases? regarding her finances as of the date meant to punish the defendant by W 21 A. Under very limited circumstances, the she was arrested. This suggests that transferring his ill-gotten gains to the H
court does not have to order restitu - the government can view any change United States Department of Justice I tion when the large number of vic - since the time of arrest as an attempt (DOJ).” 33 One goes to the victim, and T E
tims makes an order impractical, or to hide assets, even if it is prior to one goes to the government. After when the complexity of determining imposition of the restitution judg - property has been forfeited, the attor - C an amount or the extensive length of ment. 22 Similarly, with future trans - ney general has the sole authority to O
time it might take to reach a conclu - fers of property or other assets, if the decide the disposition of the proper - L L
sion would present an undue burden government suspects fraud, the gov - ty, either by retaining it or distribut - A 14 34
on the court. ernment can seek to void a transfer ing it to victims. R
with the court or attempt to collect The U.S. Attorney’s Office may Q. Does the court consider what from the third party. 23 make efforts to assist the return of C amount the client can afford to pay To determine whether a client’s forfeited property to victims through A when determining the amount of intent is meant to defraud or is free of two procedures, remission and S E 35
restitution? deceit, the court may consider several restoration. Remission requires vic - S A. No. The court must order restitu - non-exclusive enumerated factors, 24 tims to complete a petition to the tion to each victim for the full including whether the transfer was to U.S. attorney of their district demon - amount of loss the victim sustained an insider; 25 the client retained posses - strating that they suffered a loss. If regardless of the economic circum - sion and control of the property; 26 the the U.S. attorney grants the petition, stances of the defendant. 15 transfer was hidden; the transfer con - the attorney general, acting through sisted of nearly all the client’s assets; the Asset Forfeiture Money Q. Then why must the client the payment received by the client for Laundering Section (AFMLS), com - provide all her financial information? the transfer was negligible; 27 or the pensates the victim. In an approved A. After the court determines the transfer occurred close in time to the restoration, upon the request of the amount of restitution the client must restitution order. 28 If the court finds USAO, the AFMLS notifies the cus - pay, the order must specify how and fraud, cancellation of the transfer may todian of the forfeited property to when the restitution will be paid. 16 be the least of the client’s problems. transfer the proceeds to the clerk of The economic circumstances of the She may also face additional charges court for distribution to victims client influences this portion of the and a lengthier sentence if the transfer according to the restitution order. order. Based upon the client’s occurs prior to the imposition of the The restoration process avoids the finances — which includes assets, restitution order. necessity of each victim having to
WWW.NACDL.ORG JUNE 2016 21 submit a petition and simplifies the A. If more than one defendant caused Q. What are the client’s restitution process for the government. 36 the loss to a victim, the court may obligations while she is on proba - Consequently, it is generally a faster order each defendant to pay the full tion or supervised release? and more efficient way to victim restitution amount jointly and sever - A. Payment of restitution is a mandato - reimbursement. 37 ally or “may apportion liability ry condition of probation. 48 Although among the defendants to reflect the it is a discretionary condition of Q. What happens to the bond money? level of contribution to the victim’s supervised release, 49 the MVRA and a A. Where the client posted a cash loss and economic circumstances of court’s restitution order (or bond, the U.S. Attorney’s Office can each defendant.” 40 The court has full Judgment and Conviction) require ask the court to order “any money discretion to decide which option to continued payments following the belonging to and deposited by or on choose in a multidefendant matter. 41 conditions of the order. If the client behalf of the defendant” to be trans - This provision is often overlooked. If willfully fails to pay restitution while ferred to the U.S. attorney and the client agrees through her plea she is on probation or supervised applied toward payment of restitu - agreement or otherwise to pay the release, the court may revoke or tion. 38 Bond money paid by a third full restitution amount, the court will modify the terms of supervision. 50 If party (such as a family member or not allocate separate amounts due by the court chooses to revoke super - 42
S friend), however, cannot be given to each defendant. vised release and impose a term of 39 E the government. imprisonment, this act does not can - S cel the client’s restitution obligations. A Those will continue while she is C
If a client willfully fails to pay restitution while incarcerated through the IFRP and 51
R again upon release.
A on probation or supervised release, the court
L Q. Does the client’s requirement to pay L may revoke or modify the terms of supervision. restitution end when supervised O release is terminated? C
A. No. The Financial Litigation Unit of
E Q. Is there anything that can be done Q. What are the client’s restitution the U.S. Attorney’s Office maintains
T to reduce the amount a client must obligations while she is incarcerat - the responsibility for enforcing and I pay for restitution? ed and serving her sentence? monitoring restitution, even after H A. After the client begins serving the the termination of supervised W prison portion of her sentence, she release. 52 To assist the U.S. attorney
L will be asked to participate in the to continue collection after the com -
A Inmate Financial Responsibility Pro - pletion of supervised release, federal
R gram (IFRP). 43 Each institution is law requires that the client must E required to operate an IFRP with an inform the U.S. Attorney’s Office of D appointed Coordinator who is her mailing address whenever she E 53
F responsible for IFRP assignments and moves. Additionally, she must noti -
making sure inmates receive informa - fy the court and USAO of any
N tion about the program. The unit staff “material change” in her financial I 54 then counsels the client and monitors circumstances.
N payment regarding financial obliga -
O tions. Clients should elect to partici - Q. How long does the obligation to pay I pate in the program rather than refuse restitution last? T participation. Clients who refuse to A. Title 18 U.S.C. § 3613 provides that U Listen in to NACDL’s
T participate will have BOP benefits and an order of restitution “is a lien in I Podcast as host privileges withheld, such as furloughs, favor of the United States. … The T UNICOR (federal prison industries) lien arises on the entry of judgment S ivan J. Dominguez . . .
E work assignments, better housing, and continues for 20 years” from its 44
R etc. Clients can pay their court- entry or after the individual’s release ordered monetary charges from out - from imprisonment or until it is • Highlights state and federal side resources or prison work assign - satisfied. 55 Should the client die criminal justice news ments (institution, commissary, or before the 20 years have passed, the industry through UNICOR). The lien passes to the client’s estate. 56 • interviews leaders in Bureau of Prisons collects the restitu - law and public policy tion payments from the clients’ trust Q. Who distributes the restitution fund accounts or prison work earn - money to the victim? ings. 45 If the client receives an inheri - A. The Clerk’s Office disburses all Available free on iTunes and at tance, settlement, or significant restitution payments. 57 www.nacdl.org/ money from another source while she is incarcerated, she must apply the Q. What can the victims actively do to thecriminaldocket money to the restitution owed. 46 be made whole? When the client is released, BOP noti - A. Victims can request that the clerk fies the U.S. Attorney’s Office if resti - issue an abstract of judgment certi - tution is still outstanding. 47 fying the restitution order. 58 An
22 WWW.NACDL.ORG THE CHAMPION abstract of judgment is a written inform the client that the restitu - execution of the debtor’s summary of a judgment that states tion is in default and the remainder non-exempt property and how much money the client owes of the restitution amount is due filing of a fraudulent the victim. The victim can have the within 30 days. 71 transfer action. 74 abstract recorded at the county Additionally, the U.S. Attorneys’ recorder. The purpose of an abstract Manual (USAM) advises aggressive Q. What does the Federal Debt of judgment is to effect a public government collection of restitution Collection Procedures Act allow for? record and create a lien or claim if for victims and recommends the fol - A. Pursuant to the FDCPA, the govern - necessary on property owned or lowing when a client is in default: ment can bring a civil suit against the later acquired by the client located in client. Restitution qualifies as debt the county in which the abstract of [D]iscovery of the debtor’s under the FDCPA owed to a “credi - judgment is recorded. 59 If the client assets should be pursued, tor” — the government. 75 If the does not pay the judgment voluntar - including, but not limited amount of the remaining restitution ily, then the victim can force a sher - to: reviewing the presen - is greater than $50,000, the FDCPA iff’s sale of any property to collect. 60 tence report for asset infor - permits the government to seek dis - A victim may also sue the mation; requesting a finan - covery from the client in the form of
S client in civil court. If a victim cial statement from the requests for admission, interrogato -
E chooses this route, the procedural debtor or completed inter - ries, subpoenas, and depositions to S statute provides that “[a] convic - rogatories regarding assets determine her true financial condi - A tion of a defendant for an offense and liabilities; … inquiring tion. 76 The Act also allows for a writ C
involving the act giving rise to an whether any victims have of attachment on the client’s proper - 77
R order of restitution shall estop the information about the ty and writ of garnishment on 78
A defendant from denying the essen - debtor’s assets; requesting property and earnings. If the court
L tial allegations of that offense in asset information from the enters a judgment against the client, L any subsequent Federal civil pro - prosecutor and case agent; upon filing, the judgment creates a O ceeding or State civil proceeding, and, researching online lien on all the client’s real property,
C 79
to the extent consistent with State the property locator which remains in effect for 20 years. 61 E law, brought by the victim.” In services available to the The court can order the sale of the
T some circumstances, the U.S. Financial Litigation/Asset property to satisfy payment of the I Attorney’s Office may prefer that Recovery Unit. restitution 80 or the property itself can H victims sue and pursue collection In cases where the by subject to levy pursuant to a writ W on their own so that resources are United States Attorney’s of execution. 81 Until the lien is lifted,
L not unnecessarily expended by the Office has reason to believe the client may have difficulty 62 A government to seek collection. that the debtor might have applying for any federal grants,
R assets based on the inquiries loans, or programs. 82 E Q. What if the client has other monetary and research set forth above If the client makes a transfer of D obligations, such as a fine? or other information, a property to a third party, the FDCPA E
F A. Restitution takes precedence over credit report should be provides that the United States may
other criminally-imposed monetary obtained and, where practi - go after the third party if it believes
N obligations. 63 The court, in fact, cable, the deposition of the the transfer was fraudulent. 83 This I
should not order imposition of a defendant or other parties can take place regardless of whether
N fine if it would interfere with the who may have knowledge the restitution was ordered before or
O victim’s ability to receive payment of the debtor’s assets should after the transfer if the client made I of restitution. 64 be conducted. 72 the transfer with the intent to avoid T paying restitution. 84 U Q.
T Can the client discharge the debt in Further, the government is
I bankruptcy? authorized to collect restitution Q. How does state property law affect T A. Any discharge of debts pursuant to “in accordance with the practices what the government can take? S
E a Chapter 11 bankruptcy does not and procedures for the enforce - A. An order of restitution is enforceable 65
R apply to a restitution order. ment of a civil judgment under through the procedures established in Federal law or State law.” 73 The 18 U.S.C. § 3613. 85 While state law Q. What if the client does not pay? procedures for enforcement of may provide exemptions for certain A. The Financial Litigation Unit of civil judgments under federal law property belonging to a client, the the U.S. Attorney’s Office is are provided in the Federal Debt plain language of Section 3613 pre - responsible for the collection of Collection Practices Act (FDCPA). empts state law. Subsection (a) specif - restitution. 66 It can seek enforce - According to the USAM: ically states that 28 U.S.C. § 3014, a ment under federal and state law or federal statute generally permitting “by all other available and reason - All enforcement remedies, federal judgment debtors to apply able means.” 67 If the client is delin - including those under the state law property exemptions, is not quent in paying restitution (over Federal Debt Collection applicable when the government 30 days late 68 ), the U.S. Attorney’s Procedures Act, 28 U.S.C. enforces a judgment for criminal Office must notify the client of her 3001-3308, should be pur - restitution. 86 After the court orders delinquency. 69 If the payment is in sued, including garnish - restitution, all of a client’s property default (more than 90 days past ment of the debtor’s wages becomes subject to a lien in favor of due 70 ), the government must and/or bank accounts, the United States and may be gar -
24 WWW.NACDL.ORG THE CHAMPION nished following the same method as that the attorney general grant 16 did not); United States v. Minneman , 143 tax liens. 87 Thus, any property that restoration in the client’s case. 93 F.3d 274 (7th Cir. 1998). may be seized to satisfy a tax lien may Applying forfeiture money to 4. 18 U.S.C. § 3663A(a)(2). be garnished to fulfill a restitution restitution prevents the possibili - 5. 18 U.S.C. § 3664(d)(1). order. “[S]tate law exemptions are not ty of a double financial penalty 6. 18 U.S.C. § 3664(d)(2). effective against the United States” for on the client. 7. 18 U.S.C. § 3664(d)(3). taxation purposes. 88 So, too, “[s]tate 8. 18 U.S.C. § 3664(a). law exemptions are not available to a 3. Although a court has no author - 9. 18 U.S.C. § 3664(a)(4) and (6)(e). criminal defendant owing restitu - ity to require the government to 10. Id. tion.” 89 The only exemptions to treat assets previously forfeited as 11. 18 U.S.C. § 3612(b)(1). enforcement of a judgment are those restitution, its hands are not 12. 18 U.S.C. § 3613(c) and (d); USAM 3- found in Section 3613, citing specific completely tied. A court has the 12.340. If the victim is a federal agency, the tax code provisions. 90 ability to give restitution priority USAO must file a notice of lien only if the over a client’s assets that have not restitution amount exceeds $2,500. Id. Q. What can the court do if the client is yet been allocated to satisfy a for - 13. Id. 94
in default? feiture obligation. 14. 18 U.S.C. § 3663A(c)(3). See, e.g., R
A. The court continues to have power United States v. Doe , 374 F.3d 851 (9th Cir. E
when the client does not pay restitu - 4. Inform the client regarding the 2004) (government could not meet burden S tion, yet has the ability to pay. If the consequences of not paying. of proving identifiable victims, thus restitu - T I
court makes a finding that the While it would make sense that tion order was vacated). T
defendant is in default, the court the court has no jurisdiction over 15. 18 U.S.C. § 3664(f)(1)(A). U
may resentence the client to any the client after supervised release 16. 18 U.S.C. § 3664(f)(2). T I
sentence that could have originally has been terminated, the law 17. 18 U.S.C. § 3664(f)(3)(A) and (B). O been imposed, hold the client in provides otherwise. Rather, the 18. 18 U.S.C. § 3572(d)(1). N contempt of court, “enter a restrain - court maintains the power to 19. 18 U.S.C. § 3664(k). See also 18
ing order or injunction, order the resentence the client in the most U.S.C. § 3572(d)(3). Although the statutes I sale of property of the [client], enter extreme case. Equally as impor - provide that the attorney general should N
or adjust the payment schedule, or tant is the fact that the govern - be notified, this duty has been designated F
take any other action necessary to ment can sue and pursue now to the United States attorneys. See 28 E obtain compliance with the order of avenues against the client to take C.F.R. § 0.171; USAM 3-12.200. D a fine or restitution.” 91 away property and wages. 20. Id. E 21. 18 U.S.C. § 3664(d)(3). R A Q. What can the defense attorney do to 5. Advise the client of the conse - 22. See 28 U.S.C. § 3304(b). L
help the client? quences of hiding assets. The 23. 28 U.S.C. § 3306(a). A. Beyond the pain and difficulty of government may take the posi - 24. 18 U.S.C. § 3304(b)(2). W
imprisonment, the imposition of a tion that hiding, selling, transfer - 25. United States. v. Schippers , 982 F. H
hefty restitution amount imposes a ring, or devaluing assets may Supp. 2d 948 (S.D. Iowa 2013) (ex-wife I massive burden on a client and her serve as a basis for denying a considered insider where defendant T E
family. That taxing penalty cannot reduction for acceptance of transferred property pursuant to a mari - be eliminated. Instead, it is impor - responsibility and recommend - tal settlement). C tant to keep the client informed and ing an increased sentence to the 26. United States v. Sherrill , 626 F. Supp. 2d O
reduce, where permitted, the client’s court. Pre- or post-sentencing, it 1267, 1273 (M.D. Ga. 2009) (although defen - L L
obligation: may also result in additional dant transferred house to his wife, he retained A
charges to the client, including possession of the property by continuing to R
1. If the client intends to plead charges under 18 U.S.C. § 1001. live there and contributing to mortgage). guilty, negotiate the restitution 27. United States v. Forbes , 740 F. Supp. C terms of the plea agreement. In a 6. Recommend that the client par - 2d 334 (D. Conn. 2010) (no evidence that A multidefendant case, avoid ticipate in the Inmate Financial judgment debtor received reasonably S E
agreeing to the full amount of Responsibility Program while she equivalent value in exchange for transfers S restitution so that the defense is incarcerated. Voluntary partic - of his right, title, and interest in LLCs). can ask the court to apportion ipation in IFRP will allow the client 28. United States v. Holt , 664 F.3d 1147, liability and money amounts at to experience benefits — such as 1151 (8th Cir. 2011) (defendant made signif - sentencing. 92 This could signifi - work assignments, better housing, icant transfer of cash to boyfriend on the cantly reduce the amount of furloughs — that can otherwise eve of sentencing). money the client will owe over be denied in prison. 29. 18 U.S.C. § 3664(j)(1). the next 20 years of her life. 30. Id. Notes 31. 18 U.S.C. § 3663A; FED . R. C RIM . P. 2. Distinguish restitution from for - 1. See United States v. Innarelli , 524 F.3d 32.2(b)(1)(A). feiture and make sure the court is 286, 294 (1st Cir. 2008). 32. United States v. Joseph, 743 F.3d 1350 specific. When discussing the 2. 18 U.S.C. § 3663A(c)(1)(A)(ii). (11th Cir. 2014); United States v. Martinez , 610 plea agreement, request that the 3. United States v. Quarrell , 310 F.3d 664 F.3d 1216 (10th Cir. 2010); United States v. Ruff , government recommend that (10th Cir. 2002) (defendants’ conviction 472 F.3d 1044, 1047 (8th Cir. 2007); United funds recovered through forfei - under 18 U.S.C. § 371 satisfied “under this States v. Bright , 353 F.3d 1114 (9th Cir. 2004); ture be applied to restitution or title” requirement of MVRA even though United States v. Alalade , 204 F.3d 536, 539-41 that the government requests conviction for violation of ARPA under Title (4th Cir. 2000); United States v. Emerson , 128
WWW.NACDL.ORG JUNE 2016 25 2
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