United States v. Wyatt, No. 20-2382 (7th Cir. 2021)
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Wyatt victimized six women, each of whom acted as prostitutes under Wyatt’s abusive supervision in 2011-2014. He pleaded guilty to interstate sex trafficking 18 U.S.C. 1594(c). Under 18 U.S.C. 1593, Wyatt was subject to mandatory restitution to the victims for the full amount of their losses. He was sentenced to 10 years’ imprisonment. Following negotiations between the parties, oral argument, and supplemental briefing, the district court entered an order requiring Wyatt to pay $12,750 to Adult Victim 1, $45,200 to Adult Victim 3, and $37,125 to Adult Victim 5, totaling $95,075.
The Seventh Circuit affirmed, rejecting Wyatt’s arguments that the district court improperly delayed the restitution determination, did not rely on a statutorily required “complete accounting” of the victims’ losses (and relied on improper evidence), deprived him of counsel during the restitution process, and improperly ordered restitution outside of his presence. The amount of restitution was not ascertainable on the record at the time of sentencing; the court based its determination of the amounts on materials sufficient to make a reasoned restitution award.
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