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U.S. v. Keene, No. 02-2330 (1st Cir.) (341 F.3d 78) (August 22, 2003) (Judge Richard S. Arnold)

Here, joining with decisions from the Sixth, Seventh and Eleventh Circuits, the First Circuit refused to extend the Apprendi requirements to criminal forfeitures, since forfeitures are “not viewed as a separate charge” but as “an aspect of punishment imposed following conviction of a substantive offense.”

The Court stated: " For ...

 

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