United States v. Maynard and Ludwig, No. 12-5106 (2d Cir. 2014)Annotate this Case
Defendants plead guilty to committing a series of bank robberies. On appeal, defendants challenged the district court's order of restitution under the Mandatory Victims Restitution Act of 1996 (MVRA), 18 U.S.C. 3663-64. The court held that expenses other than those enumerated in section 3663A(b) were not compensable under the MVRA. In this case, the restitution order properly included the amount of money stolen during the bank robberies. However, the only portion of Merchant Bank's expenses subject to restitution was the amount paid to the bank's regular staff while the bank was closed as a crime scene. Accordingly, the court vacated the restitution component of the judgments and remanded to determine the amount of restitution.