United States v. ST CYR
1:22-cr-00185
| D.D.C. | Aug 27, 2025Background
- Yvonne St Cyr was convicted on six counts for her conduct at the U.S. Capitol on January 6, 2021, including livestreaming and encouraging others during the event.
- She was sentenced to 30 months’ imprisonment, three years’ supervised release, a $1,000 fine, $2,000 restitution, and a $270 special assessment; she paid the restitution and special assessment.
- While her appeal was pending, President Trump was inaugurated for a second term and granted a blanket pardon to all January 6 defendants, including St Cyr.
- Following the pardon, the D.C. Circuit vacated St Cyr’s conviction and remanded the case with instructions to dismiss as moot.
- St Cyr then filed a motion seeking the refund of the restitution and special assessment she had previously paid.
- The government did not oppose her motion, though similar motions by other January 6 defendants had been denied in the same district.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to Refund After Vacatur | Vacatur restores innocence and thus, requires the government to refund money paid under the conviction | Agrees that vacatur, not just pardon, commands refund | St Cyr is entitled to refund of funds paid after vacatur; government must return $2,270 |
| Effect of Pardon on Refund Entitlement | Argues that only vacatur (not pardon alone) triggers the right to a refund | Supports distinguishing vacatur from a pardon; agrees refund is due only after vacatur | Vacatur after pardon restores innocence, supporting refund even if vacatur follows a pardon |
| Appropriations Clause Authority to Refund | Asserts that courts can order refunds from Treasury under applicable statutes | Agrees with plaintiff that payment can be made via the Judgment Fund under 31 U.S.C. § 1304(a) | Court has authority to order refund from Treasury via 31 U.S.C. § 1304(a) |
| Relevance of Reason for Vacatur | Refund is required regardless of reason for vacatur | No contrary argument offered | Refund is required regardless of why the conviction was vacated |
Key Cases Cited
- United States v. Schaffer, 240 F.3d 35 (D.C. Cir. 2001) (vacatur of conviction on appeal restores presumption of innocence when appeal not resolved on the merits)
- Nelson v. Colorado, 581 U.S. 128 (2017) (government must return money exactions when a conviction is vacated; property interests are restored)
- Knote v. United States, 95 U.S. 149 (1877) (a pardon alone does not require a refund of fines or penalties previously paid)
- North Carolina v. Pearce, 395 U.S. 711 (1969) (vacated conviction erases legal grounds for continued punishment)
- United States v. U.S. Coin & Currency, 401 U.S. 715 (1971) (due process and takings issues arise if government retains property after invalidation of conviction)
- Pepper v. United States, 562 U.S. 476 (2011) (vacatur "wipes the slate clean" for sentencing purposes)
- Coffin v. United States, 156 U.S. 432 (1895) (emphasizes presumption of innocence under U.S. law)
- Johnson v. Mississippi, 486 U.S. 578 (1988) (vacated conviction no longer supports punishment or monetary exactions)
- United States v. Testan, 424 U.S. 392 (1976) (jurisdiction for claims against the U.S. under the Tucker Act)
- Office of Personnel Mgmt. v. Richmond, 496 U.S. 414 (1990) (need for substantive right to compensation for payment from Treasury)