The following excerpt is from United States v. Carter, 742 F.3d 440 (9th Cir. 2014):
In short, forfeiture and restitution are distinct concepts. See United States v. Bright, 353 F.3d 1114, 1120 (9th Cir.2004). The amount a defendant owes for one does not depend on the amount owed for the other. While forfeited assets may be applied toward satisfying restitution, they need not be. And, the value of physical assets at a particular point in time does not necessarily indicate the amount to be credited toward restitution, and perhaps a sentencing court should not tie one to the other.
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