United States v. Morris (8th Cir. July 2022)
Eighth Circuit, Fraud Cases, Restitution|
The Eighth Circuit reversed a district court’s order of restitution in a smuggling and postage counterfeiting case. The Court held that only losses caused by specific conduct that forms the basis of a conviction can be included in a restitution order, and since the defendant’s conviction was based only on his forgery of stamps and not a broader conspiracy, scheme, or pattern, the restitution should have been limited to losses caused by the forgery.