Background
Jeffrey Bradley appealed a district court order requiring the Bureau of Prisons to turn over funds from his inmate trust account to pay an outstanding restitution obligation. His counsel moved to withdraw and filed a brief challenging the amount of funds turned over.
The court’s reasoning
The court concluded that the district court did not abuse its discretion in ordering the Bureau of Prisons to turn over the amount of funds Bradley suggested in his own motion for reconsideration. The court noted that a defendant cannot complain on appeal that the court proceeded in a way that his lawyer requested.
district court did not abuse its discretion in ordering the BOP to turn over the amount of funds Bradley suggested in his own motion for reconsideration
United States v. Robinson, 44 F.4th 758, 760 (8th Cir. 2022)
What it means going forward
The decision reinforces that district courts have broad discretion in applying inmate trust funds to restitution and limits appellate challenges when the procedure was initiated by the defendant’s own counsel.
Podcast (federal-narrative-summaries): Play in new window | Download