Note:
Bonnie Arnett Von Roeder, The Right to a Jury Trial to Determine Restitution Under the Victim and Witness Protection Act of 1982, 63 Texas L. Rev. 671 (1984).
 

Abstract:
Von Roeder’s note critically analyzes the constitutional implications of the Victim and Witness Protection Act of 1982 (VMPA). The Act, which was intended to “strengthen existing legal protections for victims and witnesses of Federal Crimes,” authorizes federal courts to order defendants convicted under certain federal criminal statutes to make restitution to their victims. Although the practice of requiring restitution from convicted criminals is not a new concept, Von Roeder argues that the VMPA augments the discretionary power of federal courts in a manner that implicates serious constitutional concerns.