Manrique v. United States

Marcelo Manrique pleaded guilty to possessing child pornography. The district court imposed a sentence of imprisonment but deferred the determination of restitution. Months later, the court ordered Manrique to pay restitution to a victim known as “Vicky.” Manrique filed a notice of appeal within 14 days of that restitution order. The U.S. Court of Appeals for the Eleventh Circuit dismissed the appeal as untimely, holding that the notice should have been filed within 14 days of the original judgment that included the prison term. The Supreme Court granted certiorari to resolve a circuit split on whether a deferred restitution order is a separately appealable final judgment. The Court unanimously reversed, ruling that the restitution order was a final decision under 28 U.S.C. § 1291, and therefore Manrique’s appeal was timely when filed within 14 days of that order’s entry.

The Supreme Court reversed the Eleventh Circuit and remanded, holding that a deferred restitution order is a final sentence under § 1291, and a defendant may wait to appeal until after the restitution amount is set without losing the right to challenge the restitution order.

Whether a notice of appeal filed after entry of a deferred restitution order is timely when it is submitted within 14 days of that order but more than 14 days after the original judgment imposing imprisonment, thus determining if a deferred restitution order constitutes a final, appealable judgment.

The decision clarified appellate rights in criminal cases involving deferred restitution, ensuring that defendants can challenge restitution orders without prematurely appealing the initial conviction and sentence. It resolved a longstanding circuit split and reinforced the principle that a criminal judgment is not truly final until all sentencing components, including restitution, are fully determined.