United States v. VARGAS SANTOS
1:21-cr-00047
| D.D.C. | Jun 27, 2025Background
- Hector Emmanuel Vargas Santos was convicted for his role in the January 6, 2021, Capitol riot on four misdemeanor counts and sentenced to imprisonment, supervised release, and financial penalties.
- Vargas paid $2,026.19 towards his mandated fines, special assessment, and restitution.
- While Vargas's appeal was pending, President Trump issued a blanket pardon for all individuals convicted for January 6-related offenses, resulting in the vacatur and dismissal of Vargas’s conviction as moot.
- Vargas moved for a refund of his paid fines and restitution after his conviction was vacated; the government did not oppose the refund but stated a court order was required to effectuate it.
- The district court was asked to determine whether Vargas is legally entitled to the return of his payments, considering the money had already been deposited into the U.S. Treasury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether funds paid pursuant to a valid criminal judgment, later vacated via presidential pardon, must be refunded if already deposited into the U.S. Treasury | Nelson entitles him to refund after vacatur | Agrees refund is proper, Nelson should control | Court lacks authority to order Treasury refund per Knote |
| Applicability of Knote v. United States | Knote is outdated, inapplicable due to Nelson | Knote shouldn't control, Nelson is newer, broader | Knote governs pardons; no refund once funds are vested |
| Applicability of Nelson v. Colorado | Nelson supports mandatory refund upon vacatur | Nelson supports refund, conviction was vacated | Nelson inapplicable to pardons/Appropriations Clause |
| Statutory authority for refund under 31 U.S.C. § 1322 | -- | Refund authorized as 'erroneous deposit' | Not erroneous collection; statute doesn’t authorize |
Key Cases Cited
- Knote v. United States, 95 U.S. 149 (1877) (presidential pardon does not entitle return of funds deposited into Treasury without congressional authorization)
- Nelson v. Colorado, 581 U.S. 128 (2017) (due process requires refund of payments if conviction is vacated, but not in the context of pardons)
- In re North, 62 F.3d 1434 (D.C. Cir. 1994) (Appropriations Clause restricts refund of Treasury funds absent statute)