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Usav.Jarred Alexander Goldman

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.18-13282
DecidedMarch 25, 2020
JudgesUnited States Court of Appeals for the Eleventh Circuit
Tags
CriminalCriminal LawCriminal ProcedureRestitutionSentencingMoney, Insurance & SettlementsRipley's Believe It Or NotLegal Reality BendersVacaturRemand
Case Summary

Jarred Goldman and a codefendant stole a famous gold bar from a Florida maritime museum. The bar had been recovered from a Spanish galleon shipwreck, was uniquely associated with that recovery, and had been handled by millions of museum visitors. Goldman challenged the restitution amount imposed under the Mandatory Victims Restitution Act. The Eleventh Circuit held that market value alone could not compensate the museum for a unique artifact that could not simply be replaced with ordinary gold. The proper measure was replacement cost, including the artifact’s distinctive historical and exhibition value. The court affirmed Goldman’s sentence but vacated the restitution order because the record did not adequately establish the amount of replacement cost. It remanded for the district court to evaluate competing valuation evidence, including the reliability of premiums attributed to the bar’s history and iconic display.

Opinion

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