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Click here for the full text of this decision FACTS:David Ridgeway pleaded guilty to 22 fraud-related counts in 1992. In 1993, authorities sentenced him to 48 months of imprisonment and three years of supervised release. Authorities also fined him $50,000 and ordered him to pay $100,000 in restitution to the Louisiana Insurance Guaranty Association (LIGA). At the end of his term of supervised release, Ridgeway voluntarily executed a note with LIGA agreeing to pay at least $100 per month until his debt was paid. In 2004, more than a decade after his sentencing and years after his term of supervised release ended, the United States filed a notice of lien against Ridgeway’s property. The lien was for $150,000, which is the total of the fine plus the restitution. Ridgeway did not dispute the government’s authority to file a lien against his property for the balance of his fine; however, he contested the government’s lien insofar as it concerned the restitution order. Ridgeway argued that LIGA, not the government, was authorized to collect that debt. He filed a motion to set aside the lien and to prohibit the government’s further collection efforts on behalf of LIGA. The district court denied Ridgeway’s motion. HOLDING:Affirmed. To determine whether the government could enforce LIGA’s debt, the court scrutinized the terms of the Victim and Witness Protection Act of 1982 (VWPA), the law in effect in 1993 since repealed by the Mandatory Victim’s Restitution Act of 1996 (MVRA). The VWPA, the court stated, allowed a judge to order restitution payments immediately or in installments. Ridgeway, the court stated, focused on the provisions of the act limiting payment periods to a maximum of five years after the term of imprisonment to argue that the government no longer had authority to collect on the restitution order. The court, however, concluded that those provisions determined when payments are due. More germane, the court stated, is 18 U.S.C. �3663(h), which governs the collection of outstanding debts. The court adopted the government’s position, that: 1. �3663(h)(1)(A) allows it to utilize all methods of collection provided for in Title 18 of the United States Code, chapter 229, subchapter B; 2. one of those methods creates a lien on the fined person’s property; 3. such liens do not expire for 20 years; and 4. the underlying judgment was less than 20 years old and was therefore proper. Ridgeway’s final argument was that the note he voluntarily executed with LIGA fully satisfied his restitution debt, and the government cannot accelerate that note. But the court found that while LIGA could certainly waive its own rights to initiate a civil suit against Ridgeway to collect overdue restitution, it could not waive the government’s authority to collect restitution, as that bears uniquely on the state’s right to administer punishment. OPINION:Benavides, J.; Reavley, DeMoss and Benavides, JJ.

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