The following excerpt is from United States v. Hankins, 858 F.3d 1273 (9th Cir. 2017):
Because restitution is a criminal sentence, its enforcement is distinct from a civil judgment that is left largely in the parties' hands. "Private parties cannot simply agree to waive the application of a criminal statute." United States v. Savoie , 985 F.2d 612, 619 (1st Cir. 1993).
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