What is the test for a federal district court to determine a restitution award based on a "back-of-the-envelope" calculation?

MultiRegion, United States of America

The following excerpt is from United States v. Stratos, No. 2:11-cr-00537-TLN (E.D. Cal. 2017):

However, this not a license for a district court to engage in "back-of-the-envelope" approximations, "speculation [,or] rough justice" in determining the amount of a restitution award. See id. at 953-54. Indeed, "[r]emand is appropriate where the restitution award lacks an adequate evidentiary basis and the district court failed to explain its reasoning." Id. at 952. "The district court may utilize only evidence that possesses sufficient indicia of reliability to support its probable accuracy." United States v. Waknine, 543 F.3d 546, 557 (9th Cir. 2008) (internal

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