In the 2007 case James D. Logan v. United States, the Supreme Court ruled on a dispute over restitution in a criminal fraud case. The petitioner, James Logan, was convicted of defrauding investors and ordered to pay $19 million in restitution under the Mandatory Victims Restitution Act (MVRA). However, he argued that this amount should be reduced by any "offset" - i.e., money or assets returned to victims through other means such as civil litigation or bankruptcy proceedings. The government disagreed with this interpretation of MVRA's offset provision and maintained that it only applied when property is directly returned by an offender rather than from third-party sources like insurance companies or liquidation proceedings. The Supreme Court sided with the government's interpretation unanimously ruling that offsets under MVRA apply only to situations where property is directly returned by offenders themselves not from third parties even if they are related to their crimes indirectly.

In the dissenting opinion for James D. Logan v. United States, Justice Breyer argued that the majority's decision to uphold a restitution order against Mr. Logan was inconsistent with the language and purpose of the Mandatory Victims Restitution Act (MVRA). He pointed out that MVRA only applies to offenses committed after its enactment in 1996, while some of Mr. Logan's fraudulent activities took place before this date. Furthermore, he contended that it is unfair and contrary to principles of justice to hold an individual financially accountable for actions they undertook when there were no legal consequences attached at the time of their commission. In addition, Justice Breyer expressed concern about potential abuse by prosecutors who could use older crimes as leverage in plea negotiations or sentencing hearings under such interpretation.