9th Circ. Says Apprendi Doesn't Bar Restitution Without Victim

Law360, Los Angeles (July 11, 2013, 4:31 PM EDT) -- The Ninth Circuit upheld a $250,000 restitution order Thursday against two Hollywood producers convicted of bribing a Thai official for film festival contracts, ruling a U.S. Supreme Court ruling didn't prohibit the federal government from seeking restitution when a jury doesn't identify a victim.

The producers had argued restitution couldn't be triggered in light of the Supreme Court's 2000 decision in Apprendi v. New Jersey, which held that a jury must prove any fact, except a prior conviction, that increases the penalty for a crime beyond...
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