The following excerpt is from Fed. Ins. Co. v. United States, 882 F.3d 348 (2nd Cir. 2018):
observation that "even a thief can be the victim of a crime," 437 F.3d at 637, was hardly the controlling rationale of that case. In any event, a thief cannot be the victim of a crime when it becomes a thief precisely by turning that crime to its advantage as a way of stealing from others. Cf. United States v. Lazarenko , 624 F.3d 1247, 125052 (9th Cir. 2010) (coconspirator disentitlement doctrine applied to the victim of a kickback scheme who subsequently became a willing participant in his victimizer's conspiracy to launder the proceeds of his scheme).
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