United States Third Circuit

In a conviction of a defendant for participating in an illegal bid rigging and kickback scheme in connection with his employment, defendant's employer's appeal of the district court's denial of a request for reimbursement of the amount that it paid to one of defendant's victims is dismissed, as the employer, as a non-party, lacks standing to appeal. Further, the Mandatory Victims Restitution Act (MVRA), does not contain an implicit right of appeal by non-parties, and assuming that the exceptions permitting certain interested non-parties to appeal apply in the criminal context, none of the recognized exceptions permits the employer's appeal in this case.

Appellate Information

• Decided 08/28/2012
• Published 08/28/2012

Judges

• Vanaskie

Court

• United States Third Circuit

Counsel