Manrique v. United States

Background

Marcelo Manrique pleaded guilty after agents found more than 300 files of child pornography on his computer. The District Court sentenced him to prison and supervised release on June 24, 2014, but deferred deciding the amount of mandatory restitution. Manrique filed a notice of appeal on July 8 from that initial judgment. Months later the court held a restitution hearing, ordered $4,500, and entered an amended judgment. Manrique did not file a second notice of appeal from that amended judgment, yet he challenged the restitution amount to the Court of Appeals.

Reasoning

The Court addressed whether a single notice filed between an initial and an amended judgment can preserve review of a later-set restitution amount. The majority explained that the initial judgment and the amended restitution judgment are separate appealable orders, and that federal rules require a timely notice after the judgment being appealed. Where the Government timely objects, the requirement to file a notice after the amended judgment is a mandatory claim-processing rule that cannot be ignored. Because Manrique never filed a notice from the amended judgment imposing restitution, his challenge to the $4,500 award could not be considered.

Real world impact

The decision means defendants in cases with deferred restitution must file a separate notice of appeal after an amended judgment that sets restitution if they want to challenge the amount and the Government objects. Courts of appeals are required to dismiss such untimely appeals when the opposing party raises the filing defect. This ruling resolves the procedural path for deferred-restitution appeals but does not decide the underlying merits of restitution claims.

Dissents or concurrances

Justice Ginsburg, joined by Justice Sotomayor, argued the clerk’s transmission of the amended judgment and the district court’s failure to advise about appeal rights should allow review, and would have permitted Manrique’s challenge.