The following excerpt is from United States v. Zhou, No. 14-50288 (9th Cir. 2016):
1. Defendant also cites United States v. May, 706 F.3d 1209 (9th Cir. 2013). That case is inapposite. We never stated the applicable standard of review, and we concluded that "the district court plainly erred in ordering restitution for [a company's] expenses." Id. at 1215 (emphasis added). In short, if anything, May supports the conclusion that "plain error" review applies here.
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