Second Circuit Review: Narrowing the Bounds of 'Windfall' Restitution Awards in Financial Fraud Cases

Litigation partner Martin Flumenbaum and firm chairman Brad Karp’s latest Second Circuit Review column, “Narrowing the Bounds of ‘Windfall’ Restitution Awards in Financial Fraud Cases,” appeared in the December 26 issue of the New York Law Journal. The authors discuss U.S. v. Calderon, where the Second Circuit limited the availability of “windfall” restitution awards and narrowed its interpretation of the “proximate cause” requirement for financial fraud victims under the Mandatory Victims Restitution Act of 1996. Litigation associate Nairuby Beckles assisted in the preparation of this article.