United States v. West, No. 22-11001 (5th Cir. 2024)
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Kyle Lamar West was charged with seven counts of production of child pornography. He negotiated a plea agreement, pleading guilty to two counts in exchange for the dismissal of the other five. The plea agreement included a waiver of most of his appellate rights, but reserved the right to appeal a sentence exceeding the statutory maximum punishment. The probation office recommended a sentence of 720 months of imprisonment and $6,000 in restitution to the victim's mother. The district court adopted these recommendations.
West appealed the restitution part of his sentence, arguing that the district court failed to conduct a proximate-cause analysis as required by precedent. The United States Court of Appeals for the Fifth Circuit reviewed the case. The court noted that the district court had cited inapplicable statutes and had not conducted a proximate-cause analysis. The court also noted that the record lacked any dollar amount or range approximating the amount of the victim's losses.
The Court of Appeals found that the district court's failure to conduct a proximate-cause analysis was a clear and obvious error. The court also found that this error affected West's substantial rights and undermined the fairness, integrity, and public reputation of judicial proceedings. The court concluded that the district court had plainly erred by failing to connect West's offense conduct to the loss suffered by the victim.
The Court of Appeals vacated the district court's restitution order and remanded the case for further proceedings consistent with its opinion. The court noted that on remand, the district court could determine whether the government could present new evidence justifying the order of restitution.
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