In the case of Robers v. United States, 2013, the Supreme Court ruled that a defendant who is ordered to pay restitution for fraud must continue to reimburse victims until they have been fully compensated for their losses, even if property returned as part of that restitution has declined in value. The court's decision was based on an interpretation of the Mandatory Victims Restitution Act (MVRA), which requires defendants convicted of certain crimes to "fully compensate" their victims for their losses. Benjamin Robers had argued he should only be responsible for paying back what his fraudulent actions directly cost lenders during a real estate scheme - not additional amounts lost when properties tied up in foreclosure proceedings later sold at lower prices due to declining market values. However, Justice Samuel Alito wrote in his opinion that full compensation under MVRA covers all consequential damages resulting from fraud and does not consider subsequent changes in property value.

In the dissenting opinion for Robers v. United States, Justice Sotomayor argued that the majority's interpretation of "property" was too narrow and failed to consider other forms of restitution beyond real estate. She contended that under their definition, a victim would not be fully compensated if they were defrauded out of something other than property, such as services or money. Furthermore, she disagreed with the majority's view that victims should bear any risk associated with fluctuations in property value during foreclosure proceedings. Instead, she believed this burden should fall on the offender who caused harm in the first place by committing fraud.