U.S. v. Betts

Defendant pleaded guilty to inciting a riot in violation of the Anti-Riot Act and was sentenced to 48 months in prison and ordered to pay more than $1 million in restitution under the Mandatory Victims Restitution Act. Th court of appeals affirmed in part and vacated in part, finding that the trial court properly looked at the underlying facts of the offense to determine that the crime was an “offense against property,” but that the government failed to meet its burden of showing that defendant directly and proximately caused damages to all businesses included in the restitution order. (WOOD, concurring and HAMILTON, concurring in part and dissenting in part)