USA v. Lesley Green
Split Score
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Case Summary
Disposition
Affirmed
The court upheld the RICO conspiracy convictions, murder findings, life sentences, and restitution order. It rejected challenges to evidence, continuance denials, jury anonymity, shackling, and double-jeopardy merger, and adopted the broader reading of the MVRA that permits restitution for a victim’s family member’s lost income, noting and resolving an existing circuit split.
Circuit Split Identified
Legal Issue
Whether the Mandatory Victims Restitution Act (18 U.S.C. § 3663A) authorizes restitution to reimburse a deceased victim’s family member for the family member’s own lost income and related expenses incurred in attending court proceedings.
Circuit Positions
Family member who assumes victim’s rights may recover his/her own lost income and related expenses under § 3663A(b)(4).
Restitution cannot include family member’s personal lost income; only the deceased victim’s own losses are compensable.
Conflict Summary
Some circuits interpret § 3663A(a)(2) & (b)(4) to let a representative or family member who "assume[s] the victim’s rights" recover his or her own lost income and expenses; others read the statute as limiting restitution strictly to losses directly sustained by the actual victim (and therefore excluding the family member’s personal losses).