United States v. Skaggs, No. 22-2424 (7th Cir. 2023)
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Skaggs was convicted in 2020 of producing and possessing child pornography. The indictment had included notice that the government intended to seek forfeiture of Skaggs’s property that was seized during the investigation. Skaggs proceeded pro se with the assistance of standby counsel and was convicted. When Skaggs objected to forfeiture on the ground that some of the property sought did not relate to his crimes. The court replied that, after sentencing, it would ask the government to itemize the property and give Skaggs a chance to object. The court sentenced Skaggs to life imprisonment. The judgment included a forfeiture provision that duplicated language from the notice in the indictment: “The defendant shall forfeit all images of child pornography … and all property seized during the searches of the defendant[], his residence, and [his] laundry room.” The Seventh Circuit affirmed his conviction and sentence.
About 30 months later, well outside the 14-day period (Federal Rule of Criminal Procedure 35(a)) for correcting a sentence, at the government’s request, the court entered a preliminary forfeiture order, Itemizing each piece of property that Skaggs had forfeited, without giving Skaggs the promised chance to object. The Seventh Circuit vacated. Any forfeiture ordered at sentencing is part of the final judgment. The district court lacked the authority to amend that judgment years after its entry.
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