United States v. Roberta Sheffield

Summary

**Key Legal Topics:** Restitution; Burden of Proof; Loss Calculation; Tax Credit Fraud; Duplicate Entries. **Holding:** The Eleventh Circuit vacated the restitution order because the government's evidence—a spreadsheet containing admitted duplicate entries—was not sufficiently reliable. Where the loss from each fraudulent tax credit was a fixed $1,000 and easily calculable, the government must provide precise evidence, not merely a reasonable estimate. The case was remanded for an accurate calculation of actual refunds issued.

Holdings

1. In cases where the loss is definite and easy to calculate, the government must provide precise evidence of the actual loss, and a reasonable estimate is not sufficient. The government cannot rely on an admittedly inaccurate spreadsheet after the defendant makes a specific objection.

Questions Presented

1. Whether the district court erred in ordering restitution based on a government spreadsheet that was admittedly inaccurate and contained duplicate entries, when the loss amount was definite and easy to calculate.

Disposition

vacated