U.S. v. Woods

In Hughey v. United States, 495 U.S. 411, 110 S. Ct. 1979, 109 L. Ed. 2d 408 (1990), the Supreme Court held that under the Victim and Witness Protection Act of 1982, 18 U.S.C. §§ 3579, 3580 (recodified at 18 U.S.C. §§ 3663, 3664 as of November 1, 1987) ("VWPA"), courts have the authority to order restitution only for the offense of conviction. This appeal requires us to decide whether this rule retroactively applies to a pre-Hughey restitution order authorized under the Federal Probation Act, 18 U.S.C. § 3651 (repealed, effective November 1, 1987) ("FPA"), which has already been paid in full by the defendant.