United States v. Salti, No. 21-3183 (10th Cir. 2023)
Annotate this CaseDefendant Ahmad Salti appealed a district court’s determination of how to calculate his restitution obligation when his co-conspirator also paid some of it. Defendant was sentenced to pay the victim $35,000 in restitution, which was a “Joint and Several Amount” also owed by co-conspirator Pattrick Towner. Towner’s sentence required him to pay restitution to the victim of $72,000, owed jointly and severally with Defendant. After Defendant deposited $35,000 with the court clerk as restitution, the clerk informed the government that Defendant should receive a refund for overpayment. The clerk explained that Towner had paid $5,117.92 in restitution and the clerk had apportioned that amount pro rata between the obligation owed by both Defendant and Towner ($35,000) and the amount owed solely by Mr. Towner ($37,000). Because 35/72 of Towner’s payments ($2,487.87) had been credited to the $35,000 in restitution owed jointly and severally by both defendants, Defendant had overpaid by that amount. The government moved the district court to order the clerk not to pay Defendant a refund of $2,487.87. The district court agreed with the government, declaring that Defendant had to continue to make payments toward his $35,000 obligation unless (because of payments by Towner) the victim had already been fully compensated for its $72,000 loss. Defendant appealed. The Tenth Circuit affirmed, finding the decision of the district court maximized compensation to the victim and treated both Defendant and Towner fairly.
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