De Novo Remand Permits First-Time MVRA Restitution Despite Prior Government Disavowal, but Restitution Amount Must Follow MVRA/Rule 32 Disclosure Procedures

Introduction

In United States v. Radu Miclaus (6th Cir. May 29, 2026), the Sixth Circuit addressed what happens to restitution when a defendant wins a sentencing appeal and returns to the district court for resentencing on a general (de novo) remand. The case arose from a large-scale cyberfraud conspiracy (the “Bayrob Group”) that infected tens of thousands of computers and caused substantial victim losses. After trial, Miclaus was sentenced in 2019 to 216 months’ imprisonment without restitution—following the district court’s remark that “I don't think anybody is asking for restitution here,” and the government’s confirmation: “No, Your Honor.”

Miclaus later obtained a remand for resentencing after partial sentencing-error reversals in United States v. Nicolescu. At the 2023 resentencing, the government sought, and the district court imposed, restitution for the first time—$853,651.99 joint and several— based on figures used in a co-defendant’s (Danet’s) sealed restitution materials. Miclaus appealed again, arguing: (1) the government waived restitution at the initial sentencing; (2) he was denied access to the information underlying the restitution amount; and (3) the new restitution component was vindictive and violated due process.

The Sixth Circuit’s decision establishes a practical two-part rule for de novo resentencings: mandatory restitution may be imposed even if it was not sought (or was affirmatively disclaimed) at the first sentencing, but the amount cannot stand unless MVRA and Rule 32 disclosure procedures are honored.

Summary of the Opinion

  • Authority to impose restitution on de novo remand: The court held there was no plain error in allowing restitution to be raised and imposed for the first time on a general remand, notwithstanding the government’s initial “No” to restitution, especially because restitution was mandatory under the MVRA.
  • Process error requiring vacatur of the amount: The court held it was plain error to set restitution without providing Miclaus the loss accounting and underlying information required by the MVRA (18 U.S.C. § 3664) and Federal Rule of Criminal Procedure 32. It vacated and remanded for resentencing on the amount of restitution.
  • No due-process vindictiveness: The court rejected a presumption of vindictiveness because there was no reasonable likelihood of actual vindictiveness where restitution was statutorily mandatory and the resentencing corrected an omission.

Disposition: restitution imposition affirmed; restitution amount vacated and remanded.

Analysis

Precedents Cited

1) Scope of remand and de novo resentencing (“wipe the slate clean”)

The court grounded its “clean slate” approach in long-standing Sixth Circuit doctrine and aligned itself with the majority of circuits. The key Sixth Circuit anchor is United States v. Pembrook, which reaffirmed that on a general remand the district court may “redo the entire sentencing process” and “allow parties to raise issues even if they would have otherwise been waived.” Related Sixth Circuit cases reinforcing this broad de novo principle include:

  • United States v. Obi (district court may review sentencing matters de novo unless remand limits inquiry)
  • United States v. Garcia-Robles (general remand allows redo of entire sentencing process)
  • United States v. Moore (6th Cir.) (quoted in Garcia-Robles for de novo resentencing)
  • United States v. Jennings and United States v. Gibbs (mandate rule: district court bound by scope of remand)
  • United States v. McFalls (general remand “wipes the slate clean,” allowing government to seek harsher configuration—there, consecutive time)

The opinion also canvassed the broader circuit split, citing the “open record” / de novo view from: United States v. Tat (9th Cir.), United States v. Moore (10th Cir.), United States v. Stinson (11th Cir.), and supportive elaborations in United States v. Merrell (9th Cir.) and United States v. Dunlap (8th Cir.). It contrasted these with the “limited-by-default” approach of: United States v. Whren (D.C. Cir.), United States v. Lee (5th Cir.), United States v. Morris (7th Cir.), and United States v. Ticchiarelli (1st Cir.), and acknowledged the Second Circuit’s “middle-ground” in United States v. Quintieri.

2) Waiver/forfeiture in resentencing versus appellate-forfeiture on a second appeal

Miclaus relied on United States v. Lanier to argue the government “waived” restitution by not seeking it initially. The panel treated Lanier as addressing forfeiture and emphasized its limited persuasive value—then underscored that United States v. Pembrook (published) rejected Lanier’s logic as “foreclosed by precedent and dead on arrival.”

The court distinguished resentencing doctrine from the “appellate-forfeiture” concept (issues not raised in a first appeal cannot be raised in a second appeal), discussing United States v. McKinley as a case about appeals, not about what may be raised at de novo resentencing. It also referenced United States v. Boudreau in that appellate context. The opinion clarified the conceptual difference between forfeiture and waiver through United States v. Petlechkov and United States v. Olano.

3) Statutory and Supreme Court foundations for mandatory restitution

The MVRA’s mandatory nature was central. The court cited: In re Robinson for the proposition that the MVRA removed judicial discretion and makes restitution mandatory in covered cases, and United States v. Mitan for a recent application of MVRA requirements. Because Miclaus’s wire-fraud counts are Title 18 fraud offenses, the panel emphasized the MVRA’s “shall order” command. It cited United States v. Faulkenberry regarding wire fraud as an offense committed by fraud (supporting MVRA coverage), and United States v. McDougal for “shall order” language.

On Supreme Court authority, the opinion discussed: Pepper v. United States (general remand for de novo resentencing “wipe[s] the slate clean” and allows reconsideration of sentence components), and addressed Greenlaw v. United States (cross-appeal doctrine limits appellate courts) while explaining why it did not bar restitution here. The panel also considered the newly decided Ellingburg v. United States (restitution under MVRA is “criminal punishment” for Ex Post Facto purposes), rejecting the argument that Ellingburg implied the government may “waive” mandatory restitution.

4) Procedural protections for sentencing information (Rule 32 and due process)

For the disclosure error, the opinion relied on strict Sixth Circuit Rule 32 compliance cases: United States v. Hayes (Rule 32 disclosure protects due process), United States v. Hamad (implicit right to review other information relied upon), United States v. Marrero and United States v. Vandeberg (literal/strict compliance), and especially United States v. Coppenger (reliance on detailed undisclosed information is fundamentally at odds with Rule 32’s adversarial scheme).

5) Vindictiveness doctrine after a successful appeal

The court analyzed vindictiveness through: North Carolina v. Pearce (presumption where harsher sentence after appeal), Alabama v. Smith (presumption applies only where a reasonable likelihood of actual vindictiveness exists), Texas v. McCullough (no presumption absent realistic motive), and Sixth Circuit applications: United States v. Duso, United States v. Johnson, Goodell v. Williams, and United States v. Rodgers. The panel also cited United States v. Russ as an example where presumption can arise in a different posture (retrial after reversal).

6) Standards of review and plain error

The opinion applied plain-error review under United States v. Vonner, using the four-part framework from United States v. Schulte. It reaffirmed restitution-review standards from United States v. Church.

7) Other remand/restitution comparative authority

The court cited United States v. Garcia-Ortiz (1st Cir.) as persuasive authority rejecting a waiver argument where MVRA restitution was imposed on resentencing. It distinguished United States v. Pileggi (4th Cir.) as a limited-remand case, and noted Pileggi’s discussion of United States v. Susi about discretion to decline consideration of waived arguments—while reiterating Sixth Circuit law that a general remand permits reconsideration.

Legal Reasoning

A) Restitution could be imposed on de novo remand despite the government’s earlier “No”

The court’s reasoning proceeds in two steps.

  1. General remand = de novo resentencing authority: Because the parties did not dispute on appeal that the remand was general, Sixth Circuit precedent allowed the district court to reopen sentencing issues broadly, including issues previously forfeited or even waived. Under United States v. Pembrook and related cases, the resentencing is not constrained by what the parties did or did not argue at the first sentencing, except as limited by the mandate itself.
  2. MVRA compulsion reinforces permissibility: Even if the government’s earlier position mattered as a practical matter, the MVRA made restitution mandatory for Miclaus’s Title 18 fraud offenses. Thus, at de novo resentencing, “the district court had to order” restitution. This statutory imperative also blunted the plausibility of Miclaus’s “waiver preclusion” argument as a matter of plain error.

Critically, the panel did not endorse the government’s initial handling of restitution; it held only that, under de novo remand doctrine and the MVRA’s “shall order” command, it was not plain error to impose restitution on remand notwithstanding the prior representation.

B) The amount-setting process violated MVRA § 3664 and Rule 32—and that was plain error

After validating authority to impose restitution, the court pivoted to procedure. The MVRA (via § 3664) requires that the PSR or a separate report include “a complete accounting of the losses to each victim,” and that the court disclose to both parties the PSR/other report portions pertaining to victim losses and restitution. Rule 32 similarly requires the PSR to contain sufficient restitution information and ensures advance disclosure and opportunity to comment.

The panel found clear failures:

  • No PSR loss accounting: The PSR repeatedly stated restitution amounts were forthcoming, but never provided the accounting—before the original sentence or resentencing.
  • No disclosure of underlying data: The government referenced figures “provided” in Danet’s sentencing, but those victim-loss calculations were sealed and not provided to Miclaus.
  • First meaningful accounting arrived too late: Miclaus first received victim-by-victim amounts when attached to the resentencing judgment—after the restitution obligation was imposed.

Even though Miclaus did not object at resentencing and affirmatively stated “No objection to the restitution,” the panel held the nondisclosure was plain error because it denied notice and a meaningful opportunity to respond to information relied upon at sentencing—an error that undermines the fairness and reputation of proceedings. The remedy was targeted: vacate and remand for resentencing on the amount of restitution, with proper MVRA/Rule 32 compliance.

C) No presumption of vindictiveness where restitution is mandatory and the change corrects an omission

Because Miclaus’s post-appeal sentence included an additional punitive component (restitution), it was “more severe” than his initial sentence. But the panel held the Pearce presumption did not apply because there was no “reasonable likelihood” of actual vindictiveness. The key considerations were:

  • Mandatory nature of restitution: MVRA restitution “should have been initially imposed,” so adding it later resembled correction of a legal omission, not retaliation.
  • Error-correction principle: Under United States v. Duso, a defendant who benefits from an error bears the risk it will be corrected against him on resentencing.
  • Intervening development: Danet’s restitution judgment (and thus the figure used) occurred after Miclaus’s first sentencing—supporting that something changed besides the appeal.

With no presumption, Miclaus needed to show actual vindictiveness (United States v. Rodgers) but did not.

Impact

The decision’s practical consequences are significant for federal sentencing in the Sixth Circuit, especially in multi-victim fraud cases:

  • Restitution exposure increases on de novo resentencing: Defendants who appeal and obtain general-remand resentencings should expect that omitted mandatory components (including MVRA restitution) may be added on remand, even if the government previously failed to pursue them or disclaimed them.
  • But courts must build a disclosure-compliant record: The ruling strongly reinforces that restitution is not merely a number imported from a co-defendant’s case file—especially a sealed one. If restitution is sought on remand, district courts must ensure the PSR (or a separate restitution report) contains a complete victim loss accounting and that the defendant receives the underlying information with an opportunity to contest it.
  • Sealed co-defendant restitution materials are not a shortcut: Where the government relies on calculations from another defendant’s sentencing, it must still provide the defendant with the information necessary to test reliability and accuracy, consistent with § 3664(b) and Rule 32’s adversarial scheme.
  • Vindictiveness claims will be harder where the “increase” reflects statutory compliance: Adding mandatory restitution on remand is less likely to trigger Pearce’s presumption, particularly when the record supports correction of a prior legal omission rather than a retaliatory motive.

Complex Concepts Simplified

General remand / de novo resentencing
A remand that does not confine the district court to a narrow fix. On return, the district court may essentially resentence as if doing it for the first time, constrained primarily by the appellate mandate (and applicable statutes).
Waiver vs. forfeiture
Forfeiture is failing to raise a point in time; waiver is intentionally giving up a known right. This matters because different doctrines (and different remedies) apply—though, here, de novo resentencing doctrine largely prevented either from barring restitution on remand.
MVRA (Mandatory Victim Restitution Act)
A federal statute requiring restitution for specified offenses, including many Title 18 fraud/property crimes with identifiable victims who suffered pecuniary loss. When it applies, the court generally “shall order” restitution.
Rule 32 disclosure
Criminal Procedure Rule 32 requires that sentencing be adversarial and transparent: defendants must receive and be able to respond to information the court relies on. In restitution, that includes victim-loss data sufficient to test the amount.
Plain error
A demanding appellate standard used when no objection was made below. The appellant must show an obvious error that affected substantial rights and seriously affected the fairness or integrity of the proceedings.
Presumption of vindictiveness
A due-process doctrine from North Carolina v. Pearce that can presume retaliation when a harsher sentence is imposed after a successful appeal, but only when circumstances show a reasonable likelihood of actual vindictiveness.

Conclusion

United States v. Radu Miclaus reinforces two complementary principles in Sixth Circuit sentencing law: (1) on a general remand, the district court may impose mandatory MVRA restitution for the first time even where the government previously did not seek it (or even disclaimed it), and such imposition is not presumptively vindictive where it reflects statutory compliance; but (2) the amount of restitution cannot be imposed on the basis of undisclosed victim-loss information—particularly sealed materials from a co-defendant’s case—without the disclosures and adversarial opportunities required by the MVRA and Rule 32.

The net result is a split outcome that is likely to shape practice: defendants face meaningful risk of added mandatory restitution on de novo resentencing, while prosecutors and district courts face heightened scrutiny to ensure restitution is calculated on a record the defendant can actually see and contest.