Ellingburg v. United States
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Ellingburg v. United States and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Ellingburg v. United States.
In Ellingburg v. United States, the Supreme Court addressed whether restitution under the Mandatory Victims Restitution Act (MVRA) constitutes criminal punishment for Ex Post Facto Clause purposes. The Court determined that restitution under the MVRA is indeed criminal punishment, as it is imposed as part of sentencing for a criminal offense. The decision reversed the Eighth Circuit's ruling and remanded the case.
Holding
The single most important “bottom line” of what the Court decided in Ellingburg v. United States.
The Court held that restitution under the MVRA is criminal punishment for purposes of the Ex Post Facto Clause.
Constitutional Concepts
These are the Constitution-related themes that appear in Ellingburg v. United States. Click a concept to see other cases that involve the same idea.
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Why Ex Post Facto is relevant to Ellingburg v. United States
The case directly addresses whether the application of the MVRA to Ellingburg violates the Ex Post Facto Clause.
Syllabus excerpt (verbatim)Ellingburg raised an Ex Post Facto Clause challenge to his continued restitution obligation.
Key Quotes
Short excerpts from the syllabus in Ellingburg v. United States that support the summary and concepts above.
Restitution under the MVRA is plainly criminal punishment for purposes of the Ex Post Facto Clause.
The MVRA labels restitution as a 'penalty' for a criminal 'offense.'
The Court’s precedents have understood restitution under the MVRA to be criminal punishment.
