Robers v. United States
134 S. Ct. 1854
| SCOTUS | 2014Background
- Robers fraudulently obtained two mortgages by acting as a straw buyer and caused banks to lend about $470,000 for two houses.
- Banks foreclosed and took title to the houses in 2006; they later sold one house for about $120,000 and the other for about $160,000.
- Robers was convicted in 2010 of conspiracy to commit wire fraud and ordered to pay restitution around $220,000.
- The restitution statute MVRA §3663A(b)(1)(B) requires paying the value of property lost, less the value of any part returned as of the return date.
- Robers argued that “any part of the property returned” refers to the collateral (the houses) and thus should be valued at the time of return; the district court and Seventh Circuit rejected this interpretation.
- The Supreme Court held that “any part of the property … returned” refers to the property lost (the money lent) and not to the collateral, affecting how restitution is calculated.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of “any part of the property returned” | Robers: returns should include collateral value | United States: returns refer to property lost (money) | Returned means money lost, not collateral. |
| proximate cause and collateral timing | Robers argues market fluctuations break proximate causation | Market changes linked to offender’s fraud; collateral timing irrelevant | Market fluctuations may be proximate; collateral value timing does not undermine liability. |
| Availability of statutory tools to avoid under/over-compensation | Robers: restitution could undercompensate or overcompensate victims | Statute provides mechanisms to adjust restitution | Court may use §3664(d)(5), (f)(2)-(4) to tailor restitution; no error in interpretation. |
Key Cases Cited
- Merrill Lynch, Pierce, Fenner & Smith Inc. v. Dabit, 547 U.S. 71 (2006) (identical words used in statute presumed same meaning)
- IBP, Inc. v. Alvarez, 546 U.S. 21 (2005) (interpretation of similar statutory language)
- Muscarello v. United States, 524 U.S. 125 (1998) (rule of lenity caution in statutory construction)
- Ransom v. FIA Card Services, N.A., 562 U.S. _ (2011) (money fungibility and return of property concepts)
- Paroline v. United States, ante, at 6–11 (2014) (proximate cause framework in restitution context)
- Lexmark Int’l, Inc. v. Static Control Components, Inc., 134 S. Ct. 1387 (2014) (proximate causation and market effects in statutory interpretation)