United States v. Kidd, No. 20-2616 (8th Cir. 2022)
Annotate this Case18 U.S.C. 3664(n), which governs application of inmate account funds to restitution, does not apply to accumulated prison wages. The Eighth Circuit vacated the district court's order granting the government's Motion for Order to Authorize Payment from Inmate Trust Account, and directing the Bureau of Prisons (BOP) to turn over $5,500 from defendant's inmate trust account for payment toward his outstanding restitution obligation. The court concluded that the record on appeal does not reveal the sources of the accumulated funds in defendant's account because the district court did not hold the hearing he requested. Accordingly, the court remanded for further proceedings.
Court Description: [Loken, Author, with Smith, Chief Judge, and Wollman, Circuit Judge] Criminal case - Criminal law. Kidd appeals an order directing the application of funds from his inmate account to pay his restitution. The court agrees with the Fifth and Ninth Circuits that 18 U.S.C. Sec. 3664(n) governing application of inmate account funds to restitution does not apply to prison wages; however, the record on appeal does not reveal the sources of the accumulated funds in Kidd's account because the district court did not hold the hearing he requested, and the district court's order is vacated and the case is remanded for further proceedings consistent with this opinion.
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