On May 3rd, the Ninth Circuit considered whether the estate of a criminal defendant who dies pending appeal of his conviction stemming from a Ponzi scheme must continue to pay restitution to victims. Distinguishing between receivership and restitution orders, the Court held that because defendant consented to the receivership, his death did not abate the receivership order. Death, however, did abate the restitution order. U.S. v. Rich