Sixth Circuit - Restitution

United States v. Bailey, 973 F.3d 548 (6th Cir. 2020). The court did not err in using conspiracy principles to determine restitution, although it did err in applying those same principles to determine §2B1.1(b)(1) loss. The court could have apportioned loss among codefendants, but it was not required to do so.

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