SCM NEWS & OPINIONS

United States v. Burns, 800 F.3d 1258, 1261 (10th Cir. Sept. 10, 2015)

The court held, as a matter of first impression, that Apprendi v. New Jersey, 530 U.S. 466 (2000), does not require the jury to make factual determination underlying a restitution order beyond a reasonable doubt.