United States v. Zhang, No. 14-1382 (1st Cir. 2015)
Annotate this CaseDefendants, who each managed Chinese restaurants in Maine where undocumented immigrants were employed, pled guilty to conspiracy to harbor and aiding and abetting the harboring of illegal aliens for commercial advantage and private financial gain, conspiracy to launder money, and conspiracy to file false employer’s quarterly tax returns to the IRS. At sentencing, the district court ordered Defendants to pay restitution to the IRS. Defendants appealed, arguing that the district court erred in ordering restitution because the United States is not a “victim” for purposes of the Mandatory Victim Restitution Act. The First Circuit affirmed the restitution orders imposed by the district court, holding that the United States is a “victim” within the meaning of the Act and that a restitution award may not be offset by the value of property forfeited to the Attorney General under 18 U.S.C. 982.
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