context: Mr. Nichols contends Brewer is not controlling because it did not address the 1990 amendments to the VWPA. We disagree. As the Fourth Circuit has explained, "[n]othing in the plain language of [the amended] SS 3663(a)(2) or its legislative history usurps the settled principle that a criminal defendant who participates in a conspiracy is liable in restitution for all losses flowing from that conspiracy."
citation_a.signal: see also
citation_a.identifier: 117 F.3d 459, 463
citation_a.parenthetical: not plain error to impose restitution on each member in conspiracy based on the acts of all
citation_a.sentence: United States v. Plumley, 993 F.2d 1140, 1142 n. 2 (4th Cir.1993) (affirming restitution order under 18 U.S.C. §§ 3663-3664 where defendant argued her actions did not directly harm a robbed bank because she only drove the getaway car); see also United States v. Davis, 117 F.3d 459, 463 (11th Cir.1997) (not plain error to impose restitution on each member in conspiracy based on the acts of all). We agree with and adopt the view of our sister circuits.
citation_b.signal: no signal
citation_b.parenthetical: affirming restitution order under 18 U.S.C. SSSS 3663-3664 where defendant argued her actions did not directly harm a robbed bank because she only drove the getaway car
citation_b.sentence: United States v. Plumley, 993 F.2d 1140, 1142 n. 2 (4th Cir.1993) (affirming restitution order under 18 U.S.C. §§ 3663-3664 where defendant argued her actions did not directly harm a robbed bank because she only drove the getaway car); see also United States v. Davis, 117 F.3d 459, 463 (11th Cir.1997) (not plain error to impose restitution on each member in conspiracy based on the acts of all). We agree with and adopt the view of our sister circuits.