United States v. Bapack, Pauline Ngo

                        United States Court of Appeals


                     FOR THE DISTRICT OF COLUMBIA CIRCUIT


           Argued October 7, 1997        Decided December 5, 1997 


                                 No. 96-3172


                          United States of America, 

                                   Appellee


                                      v.


                             Pauline Ngo Bapack, 

                                  Appellant


                Appeal from the United States District Court 

                        for the District of Columbia 

                              (No. 96cr00092-01)


     Evelina J. Norwinski, Assistant Federal Public Defender, 
argued the cause for the appellant.  A.J. Kramer, Federal 
Public Defender, was on brief.

     Darryl Blane Brooks, Assistant United States Attorney, 
argued the cause for the appellee.  Mary Lou Leary, United 
States Attorney, and John R. Fisher, Thomas J. Tourish, Jr., 



and Virginia Cheatham, Assistant United States Attorneys, 
were on brief.

     Before:  Wald, Ginsburg and Henderson, Circuit Judges.

     Opinion for the court filed by Circuit Judge Henderson.

     Karen LeCraft Henderson, Circuit Judge:  A jury convict-
ed appellant Pauline Ngo Bapack of conspiring to defraud the 
Government (18 U.S.C. s 286), submitting false Medicare and 
Medicaid claims for payment (18 U.S.C. s 287), mail fraud (18 
U.S.C. s 1341) and/or aiding and abetting (18 U.S.C. s 2) 
these offenses.  She was sentenced to twenty-seven months' 
imprisonment and three years' supervised release and was 
ordered to pay $100,506.00 in restitution, reduced by approxi-
mately $38,000 based on the amount recovered in civil forfei-
ture proceedings.  She now appeals her sentence, claiming 
that it was improperly enhanced under sections 2F1.1(b)(2)(A) 
(more than minimal planning) and 3B1.1(c) (aggravating role) 
of the United States Sentencing Guidelines (Guidelines) and 
that she was erroneously ordered to pay restitution without 
regard to her ability to pay.1  We affirm.

                                I. BACKGROUND


     Bapack was the co-owner of Urgent Home Health Care 
Services, Inc. (Corporation), which provided nursing care to 
Medicaid and Medicare patients in their homes.  She was 
responsible for billing Medicaid for the services the Corpora-
tion provided.  Because Medicaid and Medicare pay only for 
services actually rendered, a home health care agency like the 
Corporation simply cannot bill for the services prescribed in 
the patient's Plan of Care (Plan).  Instead the provider can 

__________
     1 Section 2F1.1(b)(2) of the Guidelines provides that "[i]f the 
offense involved (A) more than minimal planning, ... increase [the 
sentence] by 2 levels," and section 3B1.1(c) of the Guidelines states 
that "[i]f the defendant was an organizer, leader, manager, or 
supervisor in any criminal activity ... increase [the sentence] by 2 
levels."  United States Sentencing Commission, Guidelines Manu-
al, s 2F1.1(b)(2)(A) & s 3B1.1(c) (Nov. 1995).



bill Medicaid and Medicare only for the number and kinds of 
treatment visits in fact made, which, for a variety of reasons, 
may differ from those prescribed in the patient's Plan.  Thus, 
the provider typically generates billing invoices by reference 
to attending nurses' time sheets, treatment notes and other 
records.

     The Corporation, however, did not do this.  Instead, at 
Bapack's (and co-defendant Pierre Yopa's) direction, it billed 
Medicaid and Medicare for the number and type of visits 
prescribed in the patient's Plan.  As a result, it remitted 
numerous invoices for services it did not perform;  the evi-
dence presented at trial established that the Corporation, 
under the superintendence of Bapack and Yopa, billed Medic-
aid and Medicare for more than 1,400 nurse visits that could 
not be substantiated, the value of which totaled approximately 
$100,506.00.

     On a tip from a former Corporation employee, the Inspec-
tor General's Office of the United States Department of 
Health and Human Services learned of the billing practices 
and raided the Corporation's offices in November 1995.  Af-
ter reviewing the records seized, and after subpoenaing sev-
eral Corporation nurses to testify, the grand jury returned an 
eighteen-count indictment against Bapack and her co-
defendant, Pierre Yopa.  Yopa was the other co-owner of the 
Corporation and he was responsible for Medicare billing.

     The Government's evidence included the testimony of Di-
ane Bouchaud, a nurse who had been a case manager for the 
Corporation.  Bouchaud testified that Bapack directed her 
and other nurses to falsify records of nursing visits that were 
not made.  See 9/10/96 Trial Tr. 325, 333-36, 338.  Zuliatu 
Sillah, another nurse who served as the Corporation's Acting 
Director of Nursing, testified that Bapack had instructed her 
and others to fabricate records of nursing visits to assist in 
meeting a survey administered by the District of Columbia 
Department of Consumer and Regulatory Affairs (DCRA).  
Id. at 412-13, 418-19, 436-38.  The Corporation was required 
to meet DCRA requirements, including complying with the 
surveys, to be a certified Medicare provider.



     On September 16, 1996, the jury returned a general ver-
dict, finding both Bapack and Yopa guilty on all counts.  The 
district court sentenced Bapack on December 9, 1996.  Con-
cluding that her offenses involved "more than minimal plan-
ning," it enhanced her sentence by two levels pursuant to 
section 2F1.1(b)(2)(A) of the Guidelines.  12/9/96 Sentencing 
Tr. 20.  The court also found that, under section 3B1.1(c) of 
the Guidelines, an additional two-level enhancement was ap-
propriate for Bapack's role as an "organizer, leader, manager, 
or supervisor":

     Well, [appellant] clearly was, at the very least, a manager 
     or supervisor.  There was at least more than one partici-
     pant other than Ms. Bapack herself.  The testimony is 
     that she was, in fact, a manager of the enterprise that 
     was found guilty of defrauding Medicare.

Id. at 18.  The presentence investigation report (Report), 
which the district court adopted in the Judgment in a Crimi-
nal Case (Judgment), also recited that "[f]ormer employees 
testified that Ms. Ngo Bapack, [sic] asked some of the staff 
members to create nursing records so that the patient's file 
would falsely reflect that nurses had followed the doctors' 
orders and reflect that the nurse visits had been consistent 
with the 'Plans of Care.' "  11/20/96 Report p 11.

     Finally, the district court ordered Bapack to pay restitu-
tion:

     You shall pay a total restitution in the amount of 
     $100,506....  The Court finds you do not possess the 
     ability to pay a fine, the cost of imprisonment, or supervi-
     sion unless otherwise determined by the Bureau of Pris-
     ons.  In view of your financial status and your need to 
     secure employment upon release to begin paying your 
     restitution payments, an alternative sanction is not rec-
     ommended....  Finally, I want to note for the record 
     that there is a companion civil case that's running along-
     side this case.  It's a forfeiture case....  And the effect 
     of that forfeiture entered on the sentencing in this case is 
     as follows:  It doesn't affect the level of loss for purposes 
     of the sentence.  But I believe it will operate to reduce 



     the amount of restitution that [co-defendant] and Ms. 
     Bapack will have to make.  And so the final orders will 
     reflect a restitution amount which is the approximately 
     hundred thousand dollars that I recited minus the ap-
     proximately $38,000 that has been seized and forfeited.  
     And also, for the record, that restitution amount will 
     necessarily be joint and several for whatever effect that 
     has if Mr. Yopa is ever apprehended and returned and 
     sentenced.

12/9/96 Sentencing Tr. 22, 24 (reporter's indenting and para-
graph structure omitted).  The Report noted "[b]ased on her 
current financial status, it does not appear that [appellant] 
has the ability to pay a fine, the costs of incarceration and/or 
supervision, in addition to her restitution obligation, if or-
dered by the court."  11/20/96 Report p 57.  It also noted that 
"the Government reported that when the seizure warrant was 
executed on March 4, 1996, the defendant had a [bank] 
balance of $102,645.17." 2  Id.  The district court then or-
dered Bapack to pay restitution in the amount of 
$62,294.50.3  Bapack contested neither the restitution order 

__________
     2 The Government's sentencing memorandum indicated that this 
amount was held in two Crestar Bank accounts.  (Appellee App. 
Tab H at 10 n.4.)  Neither the sentencing memorandum nor the 
Report indicates, however, whether and to what extent Bapack (as 
distinguished from her co-defendant) had access to the accounts.  
Moreover, there is no record indication that the district court relied 
on this information in ordering restitution.

     3 Bapack's Judgment orders restitution in the amount of 
$72,294.50, which is $10,000.00 more than the district court's oral 
sentence.  The Government attributes the difference to a simple 
arithmetic error:  the amount of loss, $100,506.00, less the amount 
recovered in forfeiture proceedings, $38,211.50, should have resulted 
in a restitution order in the amount of $62,294.50, not $72,294.50.  It 
suggests that we let the district court resolve the matter without 
remand (pursuant to Fed. R. Crim. P. 36) and without delaying 
consideration of the merits.  See Appellee Br. at 25 n.14.  We think 
the preferable procedure is to conform the written sentence to the 
oral one.  See Bartone v. United States, 375 U.S. 52, 53 (1963) 
("This error, in enlarging the sentence in the absence of petitioner, 



nor the enhancement for more than minimal planning.  She 
did argue, however, that there was insufficient evidence to 
support the aggravating role enhancement.  12/9/96 Sentenc-
ing Tr. 12-13.  Bapack timely appealed and we now affirm.

                                II. DISCUSSION


                       A.  Aggravating Role Enhancement


     Bapack first contends that because there was no evidence 
to establish her role as a supervisor or manager of another 
participant in the crimes with which she was charged, the 
district court erred in enhancing her sentence pursuant to 
section 3B1.1(c) of the Guidelines.  We review the sentencing 
court's finding for clear error.4  See United States v. Baylor, 
97 F.3d 542, 548 (D.C. Cir. 1996);  United States v. Kelley, 36 
F.3d 1118, 1128 (D.C. Cir. 1994) ("[W]e give due deference to 
the district court's application of the sentencing guidelines to 
the facts, and we accept the district court's findings of fact 
unless they are clearly erroneous.").

     At sentencing, it is the Government's burden to demon-
strate by a fair preponderance of the evidence that an en-
hancement is warranted.  See United States v. Cruz, 120 F.3d 
1, 2 (1st Cir. 1997) (en banc).  Thus, to support an aggrava-
ting role enhancement, the Government must show that more 
likely than not the defendant organized, led, managed or 
supervised the crime.  See United States Sentencing Com-

__________
was so plain in light of the requirements of Rule 43 that it should 
have been dealt with by the Court of Appeals, even though it had 
not been alleged as error.").  Accordingly, we hereby conform the 
written and oral restitution orders, revising the Judgment to re-
quire restitution of $62,294.50, the amount the district court plainly 
intended to order.

     4 While she also asserts the district court applied the wrong legal 
standard (Appellant Br. 8), we find nothing in the sentencing 
transcript to support her assertion.



mission, Guidelines Manual, s 3B1.1 application note 2 
[hereinafter Guidelines Manual].5  The Guidelines direct the 
sentencing judge to consider several factors, including

     the exercise of decision making authority, the nature of 
     participation in the commission of the offense, the re-
     cruitment of accomplices, the claimed right to a larger 
     share of the fruits of the crime, the degree of partic-
     ipation in planning and organizing the offense, the nature 
     and scope of the illegal activity, and the degree of control 
     and authority exercised over others.

Id. application note 4;  accord United States v. Thomas, 114 
F.3d 228, 261 (D.C. Cir. 1997) ("The Sentencing Guidelines 
instruct the sentencing court to consider the numerous fac-
tors listed above, no one of which is determinative.") (empha-
sis added), petition for cert. filed, No. 97-6660 (U.S. Nov. 6, 
1997).

     Mere "control over a scheme rather than over a participant 
in a scheme," however, does not warrant a sentencing adjust-
ment pursuant to section 3B1.1(c).6  United States v. Gort-

__________
     5 The Commentary to the Guidelines binds the sentencing court 
to the same extent as the Guidelines themselves.  See Stinson v. 
United States, 508 U.S. 36, 45 (1993).

     6 The Commentary recites that "[a]n upward departure may be 
warranted, however, in the case of a defendant who did not orga-
nize, lead, manage, or supervise another participant, but who never-
theless exercised management responsibility over the property, 
assets, or activities of a criminal organization."  Guidelines Manu-
al, s 3B1.1 application note 2.  Because the district court indicated 
that it was adjusting Bapack's sentence, rather than upwardly 
departing, however, we cannot affirm the sentence on the basis of 
her evident role in exercising "management responsibility over the 
property, assets, or activities of" the Corporation.  See United 
States v. Jobe, 101 F.3d 1046, 1048 (5th Cir. 1996) ("As the district 
court did not order an upward departure, this ground of enhance-
ment is unavailable to sustain the enhancement on appeal."), cert. 
denied 118 S. Ct. 81 (1997);  but cf. United States v. Giraldo, 111 
F.3d 21, 24 (5th Cir. 1997) (although sentencing judge improperly 
relied on asset management theory to adjust sentence instead of 
upwardly departing, court declined to vacate sentence because 
evidence also supported adjustment making Guidelines application 
error harmless).



DiDonato, 109 F.3d 318, 322 (6th Cir. 1997) (emphasis added).  
Instead "the defendant must have been the organizer, leader, 
manager, or supervisor of one or more participants."  Guide-
lines Manual, s 3B1.1 application note 2 (emphasis added).  
A "participant" is a "person who is criminally responsible for 
the commission of the offense, but need not have been 
convicted."  Id. application note 1.  In turn, a person is 
"criminally responsible" if he "commit[s] all of the elements of 
a statutory crime with the requisite mens rea."  United 
States v. Badaracco, 954 F.2d 928, 934-35 (3d Cir. 1992).  
This does not mean, however, that to qualify as a "partici-
pant" a person must be found criminally responsible as a 
principal or culpable in the same crime of which the supervis-
ing defendant was convicted:  "[J]ust as a party who knowing-
ly assists a criminal enterprise is criminally responsible under 
principles of accessory liability, a party who gives knowing 
aid in some part of the criminal enterprise is a 'criminally 
responsible party' under the Guidelines."  United States v. 
Hall, 101 F.3d 1174, 1178 (7th Cir. 1996).  Thus, "the facts 
that none of [the participants] benefitted from the commission 
of the offense or were convicted of any offenses arising from 
the criminal activity do not necessarily determine the ultimate 
issue."  United States v. Braun, 60 F.3d 451, 453 (8th Cir. 
1995).

     Bapack argues that none of the nurses who falsified treat-
ment records and time sheets at her instruction can be 
considered criminally responsible for the crimes of which she 
was convicted because (1) none of the nurses was involved in 
the billing and (2) the falsified records were not used to bill 
Medicaid or Medicare but instead were used only to meet the 
DCRA certification survey.  In her view, therefore, none of 
the supervised nurses had "the specific intent to facilitate 
Medicare/Medicaid fraud."  (Appellant Reply Br. 3.)  In 
short, Bapack asserts that, to the extent the nurses she 
supervised contributed to the offenses of which she was 
ultimately convicted, they did so unwittingly.7

__________
     7 She also argues that the only other "participant" in the charged 
crimes, her business partner and co-defendant Yopa, was not shown 



     Her contentions are beside the point as they are mistakenly 
predicated on the assumption that only supervision of "partic-
ipants" in the crimes with which she was charged, or of which 
she was convicted, warrants a section 3B1.1(c) enhancement.  
To the contrary, as provided by the Guidelines as well as 
circuit precedent, "[t]he determination of a defendant's role in 
the offense is to be made on the basis of all conduct within 
the scope of s 1B1.3 ... and not solely on the basis of 
elements and acts cited in the count of conviction." 8  Guide-
lines Manual, s 3B1.1 introductory commentary (emphasis 
added);  accord United States v. Caballero, 936 F.2d 1292, 
1298 (D.C. Cir. 1991) ("[W]e conclude that section 3B1 allows 
the sentencing judge to look to the contours of the underlying 

__________
or even alleged to have been supervised, managed or led by her.  
Because we find sufficient evidence that Bapack supervised nurses 
in the commission of certain crimes with which both she and the 
involved nurses could have been charged, we do not reach the issue 
of Bapack's role vis--vis her co-defendant.

     8 Section 1B1.3 defines "relevant conduct" as:

     (1)(A) all acts and omissions committed, aided, abetted, coun-
     seled, commanded, induced, procured, or willfully caused by the 
     defendant;  and (B) in the case of a jointly undertaken criminal 
     activity (a criminal plan, scheme, endeavor, or enterprise un-
     dertaken by the defendant in concert with others, whether or 
     not charged as a conspiracy), all reasonably foreseeable acts 
     and omissions of others in furtherance of the jointly undertak-
     en criminal activity, that occurred during the commission of the 
     offense of conviction, in preparation for that offense, or in the 
     course of attempting to avoid detection or responsibility for 
     that offense;  (2) solely with respect to offenses of a character 
     for which s 3D1.2(d) would require grouping of multiple 
     counts, all acts and omissions described in subdivisions (1)(A) 
     and (1)(B) above that were part of the same course of conduct 
     or common scheme or plan as the offense of conviction;  (3) all 
     harm that resulted from the acts and omissions specified in 
     subsections (a)(1) and (a)(2) above, and all harm that was the 
     object of such acts and omissions;  and (4) any other informa-
     tion specified in the applicable guideline.

Guidelines Manual, s 1B1.3(a)(1)-(4) (emphasis added).



scheme itself rather than the mere elements of the offense 
charged.") (internal quotations omitted;  emphasis added), 
cert. denied, 502 U.S. 1061 (1992).  Accordingly, the district 
court was free to consider Bapack's role with respect to all 
crimes, charged or otherwise, "that were part of the same 
course of conduct or common scheme or plan as the offense of 
conviction."  Guidelines Manual, s 1B1.3(a)(2).9  In other 
words, application of the section 3B1.1(c) enhancement does 
not require a finding that Bapack supervised "participants" 
who were unindicted co-conspirators or accessories in the 
crimes of which she was convicted.  Rather, it is enough that 
the "participants" she supervised were culpably involved in 
uncharged crimes "that were part of the same course of 
conduct or common scheme or plan as the offense of convic-
tion."  Id.

     We therefore have no trouble concluding that Bapack su-
pervised or managed at least one other "participant."  Specif-
ically, the testimony of at least two Corporation nurses 
(Bouchaud and Sillah), as well as the representations made in 
the Report, establish by well more than a fair preponderance 
of the evidence that Bapack supervised the knowing creation 
of a materially false document.10  Although the Government 
elected not to pursue it, the knowing falsification of records is 
a violation of 18 U.S.C. s 1001, for which both Bapack and 
the involved nurses could have been prosecuted.11  The nurs-

__________
     9 Section 1B1.3(a)(2) of the Guidelines applies because section 
3D1.2(d) requires that Bapack's fraud and conspiracy convictions be 
grouped.

     10 Indeed, Bouchaud's testimony was so suggestive of her criminal 
culpability it prompted defense counsel to inquire whether she had 
been granted immunity.  See 9/10/96 Trial Tr. 336:11-338:16.

     11 Section 1001, in relevant part, provides:

     [W]hoever, in any matter within the jurisdiction of the execu-
     tive, legislative, or judicial branch of the Government of the 
     United States, knowingly and willingly--... (2) makes any 
     materially false, fictitious, or fraudulent statement or represen-
     tation;  or (3) makes or uses any false writing or document 
     knowing the same to contain any material false, fictitious, or 



es' actions were indisputably "part of the same course of 
conduct or common scheme or plan as the offense[s]" of which 
Bapack was convicted.  Although they admitted only that 
they falsified records for the DCRA certification require-
ments, a jury might reasonably disbelieve their knowledge 
was so limited and conclude from the totality of the circum-
stances that the nurses were well aware that the falsified 
records would ultimately be submitted to the Medicaid pro-
gram.12  Accordingly, the district court did not clearly err in 
finding Bapack played an aggravating role in the offenses.

                    B. Cumulative Application of Sections 

           3B1.1(c) and 2F1.1(b)(2)(A)

     Bapack next argues that by cumulatively enhancing her 
sentence for her managerial role and for more than minimal 
planning, the sentencing court punished her twice for the 
same conduct.  Since Bapack did not raise the double-
counting argument below, we review the district court's deci-
sion for plain error.  See United States v. Plunkett, 125 F.3d 
873, 874-75 (D.C. Cir. 1995).  The Guidelines provide:

     Absent an instruction to the contrary, the adjustments 
     from different guideline sections are applied cumulatively 

__________
     fraudulent statement or entry;  shall be fined under this title or 
     imprisoned not more than 5 years, or both.

18 U.S.C.A. s 1001(a) (West Supp. 1997) (paragraph structure 
omitted).  Bouchaud's testimony (see supra note 10,) also suggested 
that she might have been prosecuted for submitting false claims in 
violation of 18 U.S.C. s 287, providing yet another basis for enhanc-
ing Bapack's sentence pursuant to section 3B1.1(c).

     12 In any event, because DCRA acts as an agent for the United 
States Department of Health and Human Services (HHS) regarding 
D.C. Medicare certifications, 9/9/96 Trial Tr. 200-205, the DCRA 
survey itself may qualify as a "matter within the jurisdiction of the 
executive ... branch of the Government of the United States."  Cf. 
United States v. Murphy, 935 F.2d 899, 900 n.1 (7th Cir. 1991) ("As 
we have previously held, HHS' regulatory oversight and provision 
of funding for Illinois' AFDC program establishes the applicability 
of s 1001 to that program.").



     (added together).  For example, the adjustments from 
     s 2F1.1(b)(2) (more than minimal planning) and 
     s 3B1.1 (Aggravating Role) are applied cumulatively.

Guidelines Manual, s 1B1.1 application note 4(p 2) (emphasis 
added).  Nevertheless Bapack encourages us to set aside the 
enhancement for more than minimal planning, asserting that 
the holding in United States v. Gottfried, 58 F.3d 648, 653 
(D.C. Cir. 1995), supports her.  We disagree.  In Gottfried, 
we had to decide whether enhancements for more than mini-
mal planning and for abuse of a position of trust were 
duplicative.  See 58 F.3d at 652-53.  We held that, because 
the two enhancements were based on separate elements of 
the defendant's offense, their cumulative application did not 
punish him twice for the same conduct.  Id. at 653.  In 
Gottfried we noted in dicta two Sixth Circuit cases "to the 
same effect."  Id.  Although those cases--United States v. 
Chichy, 1 F.3d 1501, 1507 (6th Cir. 1993), and United States 
v. Romano, 970 F.2d 164, 167 (6th Cir. 1992)--held that 
enhancements for an organizing role and for more than 
minimal planning could be impermissibly duplicative, they did 
not involve a situation in which a different element supported 
each enhancement.  Bapack's case is plainly distinguishable 
from those cases because her sentence was enhanced for her 
managerial/supervisory role and for more than minimal plan-
ning.  Moreover, as the Sixth Circuit has since acknowledged, 
both Chichy and Romano were overruled in 1993 when the 
Sentencing Commission amended the Commentary to section 
1B1.1 to include the unequivocal language quoted above.  See 
United States v. Cobleigh, 75 F.3d 242, 251 (6th Cir. 1996) 
("The Sentencing Commission's regulations have thus abro-
gated the holdings of Romano and Chichy.").  [B]ecause "the 
force of the [Guidelines] commentary is near complete," Unit-
ed States v. Smaw, 22 F.3d 330, 333 (D.C. Cir. 1994), we, like 
the Sixth Circuit, think that Application Note 4 to section 
1B1.1 of the Guidelines is dispositive.

     The enhancements Bapack received were based on differ-
ent elements of the offenses of which she was convicted.  The 
aggravating role enhancement (as Bapack herself argues) was 
based on her directing nurses to falsify records of treatment 



visits that were not made whereas the more than minimal 
planning enhancement was based on the overarching fraudu-
lent billing scheme Bapack and her co-defendant engineered.  
Thus, contrary to her contention, Bapack was not found to 
have engaged in more than minimal planning because she 
supervised or managed a "participant," nor was she found to 
have supervised or managed a "participant" because she 
engaged in more than minimal planning.  Accordingly, the 
district court did not err, much less plainly err, in cumulative-
ly applying sections 3B1.1(c) and 2F1.1(b)(2)(A) of the Guide-
lines to enhance Bapack's sentence.

                           C. The Restitution Order


     Finally Bapack contends that the district court erred in 
ordering restitution both because it apparently failed to con-
sider her ability to pay and because the available evidence 
demonstrated that she could not make restitution.13  Bapack 
specifically asserts that, as the Report indicates, she has four 
minor children living in Cameroon, her debts exceed her 
assets and she is subject to deportation proceedings upon 
release from federal custody.  For these reasons, she asserts, 
the court erred in ordering restitution in any amount.  Be-
cause Bapack did not contest the restitution order below, we 
review it for plain error.  See Plunkett, 125 F.3d at 874-75;  
United States v. Davis, 117 F.3d 459, 462 (11th Cir.), cert. 
denied, 118 S. Ct. 355;  United States v. Zink, 107 F.3d 716, 
718 (9th Cir. 1997);  United States v. Castner, 50 F.3d 1267, 
1277 (4th Cir. 1995).

     The Guidelines direct that "[i]n determining whether to 
impose an order of restitution, and the amount of restitution, 
the court shall consider the amount of loss the victim suffered 

__________
     13 Although the restitution provisions of Title 18, 18 U.S.C.A. 
ss 3663 et seq. (West Supp. 1997), have recently been amended to 
make restitution mandatory in cases like this one, we apply the 
provisions in effect at the time Bapack was sentenced.  See United 
States v. Thompson, 113 F.3d 13, 15 n.1 (2d Cir. 1997) (concluding 
that retroactive application of mandatory restitution provisions rais-
es ex post facto concerns).



as a result of the offense, the financial resources of the 
defendant, the financial needs of the defendant and his depen-
dents, and other factors the court deems appropriate."  
Guidelines Manual, s 5E1.1 background p 3 (paraphrasing 
18 U.S.C. s 3664(a)).  The Guidelines do not, however, re-
quire a sentencing judge to make specific factual findings 
regarding the factors.  On the contrary, they instruct that 
"[i]f the court does not order restitution or orders only 
partial restitution, it must state its reasons for doing so."  Id. 
background p 2.

     As we have observed in the analogous context of assessing 
a defendant's ability to pay a fine, because

     [t]he guidelines set forth no requirement ... that the 
     sentencing court make express findings on this ques-
     tion[,] ... we decline to create one.  So long as the 
     sentencing judge in fact considers ability to pay, he is in 
     compliance with the guidelines' mandates.  Thus, where 
     the record demonstrates that the judge considered that 
     factor before imposing the fine, the appellate court will 
     not reverse the fine merely because no express finding 
     was made but will review the finding of ability to pay 
     necessarily implied by such consideration.

United States v. Mastropierro, 931 F.2d 905, 906 (D.C. Cir. 
1991).  In applying this rule, we join the clear majority of our 
sister circuits.  See, e.g., Davis, 117 F.3d at 463 (11th Cir. 
1997) (noting that specific factual findings not required);  
United States v. Sanders, 95 F.3d 449, 456 (6th Cir. 1996) 
(similar);  United States v. Giwah, 84 F.3d 109, 114 (2d Cir. 
1996) (similar);  United States v. Newman, 49 F.3d 1, 10 (1st 
Cir. 1995) (similar);  United States v. Gio, 7 F.3d 1279, 1291 
(7th Cir. 1993) (similar);  United States v. Ramilo, 986 F.2d 
333, 335 (9th Cir. 1993) (similar);  United States v. Rogat, 924 
F.2d 983, 986 (10th Cir.) (similar), cert. denied, 499 U.S. 982 
(1991);  United States v. Ryan, 874 F.2d 1052, 1053 (5th Cir.) 
(concluding that legislative predecessor to 18 U.S.C. 
s 3664(a) 



did not require specific findings), cert. denied, 489 U.S. 1019 
(1989).14

     We conclude that the record adequately evinces the district 
court's consideration of Bapack's ability to pay, the only one 
of the required factors she challenges.  In particular, we note 
that the court adopted the unchallenged ability-to-pay find-
ings of the Report, which discussed Bapack's financial worth, 
past work history and future ability to pay.  The judge also 
stated "[t]he Court finds you do not possess the ability to pay 
a fine, the cost of imprisonment, or supervision[;] ... [i]n 
view of your financial status and your need to secure employ-
ment upon release to begin paying your restitution payments, 
an alternative sanction [fines, etc.] is not recommended."  
12/9/96 Sentencing Tr. 22.  These indicia of the court's consid-
eration of Bapack's ability to pay restitution satisfy us that it 
considered the required factors in ordering her to pay restitu-
tion.  See Davis, 117 F.3d at 464 (record reflected consider-
ation of defendant's ability to pay where sentencing judge 
adopted presentence report regarding defendant's financial 
circumstances and where defendant was given opportunity to 
object but did not);  Castner, 50 F.3d at 1278 (sentencing 
judge's failure to make specific factual findings regarding 
defendant's ability to pay restitution was not plain error 
where judge adopted presentence report that considered 18 
U.S.C. s 3664(a) factors);  United States v. Mizrachi, 48 F.3d 
651, 657 (2d Cir. 1995) (upholding restitution order where 
presentence report contained detailed discussion of 18 U.S.C. 
s 3664(a) factors and where court mentioned restitution in 
connection with its decision not to assess fine or incarceration 
costs);  Nelson, 5 F.3d at 258 (record reflected consideration 
of defendant's ability to pay restitution where sentencing 
judge determined "[d]efendant does not have a financial 
ability to pay a fine, costs of incarceration, community con-
finement, or supervision, and, therefore, [the court] waives 

__________
     14 We therefore reject the approach of the Third Circuit and the 
Fourth Circuit, which seem to require specific findings as to each of 
the factors listed in 18 U.S.C. s 3664(a).  See United States v. 
Copple, 74 F.3d 479, 482 (3d Cir. 1996);  United States v. Piche, 981 
F.2d 706, 718 (4th Cir. 1992), cert. denied, 568 U.S. 916 (1993).



the interests on the fine, costs of incarceration, community 
confinement and supervision in this case").

     The cases Bapack relies on are easily distinguished from 
hers.  In Thompson, 113 F.3d at 16, the Second Circuit was 
not satisfied that the sentencing judge had considered the 
required factors because, unlike here, the judge refrained 
from fining the defendant without comment on the defen-
dant's ability to pay either a fine or restitution.  In Sanders, 
95 F.3d at 456, the sentencing judge stated that he was 
"required" to order restitution whereas his restitution order 
was instead held to be discretionary and the Sixth Circuit was 
uncertain, in view of a silent record, that the required factors 
had been considered.  There is nothing in the record here 
that leads us to conclude that the district court believed it had 
to order restitution and thus Sanders is inapposite.  Finally, 
in United States v. Remillong, 55 F.3d 572 (11th Cir. 1995), 
the Eleventh Circuit remanded the defendant's sentence to 
the district court for the third time because the only evidence 
of consideration of the required factors consisted of the 
sentencing judge's handwritten note on the Judgment, which 
indicated only that restitution was appropriate because the 
defendant had at one time had physical custody of the stolen 
money.  See 55 F.3d at 574.

     Nor do we find plain error in the sentencing court's conclu-
sion that Bapack should be ordered to pay restitution in the 
amount of $62,294.50.  Bapack bore the burden at sentencing 
of demonstrating by a fair preponderance of the evidence her 
financial condition.  See 18 U.S.C. s 3664(d) ("The burden of 
demonstrating the financial resources of the defendant and 
the financial needs of the defendant and such defendant's 
dependents shall be on the defendant.").  To prevail on 
appeal she must "show that the record is devoid of any 
evidence that [she] is able to satisfy the restitution order."  
Davis, 117 F.3d at 459 (internal quotation marks omitted;  
emphasis added).  The "burden is particularly acute under 
the plain error standard of review."  Id.  Bapack has not 
satisfied her appellate burden, as the Report's unchallenged 
ability to pay findings suffice to sustain the restitution or-



der.15  See United States v. Twitty, 107 F.3d 1482, 1494 n.14 
(11th Cir.) (sentencing court entitled to rely on uncontrovert-
ed findings of presentence report in deeming defendant able 
to pay restitution), cert. denied, 118 S. Ct. 253 (1997).  Ac-
cordingly, we conclude that the district court did not plainly 
err in ordering Bapack to pay restitution in the amount of 
$62,294.50.  Cf. Castner, 50 F.3d at 1278 ("Although Appel-
lants at time of sentencing had a negative net monthly cash 
flow, this does not necessarily indicate an inability to pay, 
particularly when their [presentence reports] reflect past 
success in business and above average earning capacities.");  
Nelson, 5 F.3d at 259 (holding that although defendant had 
negative net worth at time of sentencing, record indicated he 
"demonstrated considerable talent in perpetrating his 
crime[,]" and thus "[t]he restitution order gives [him] an 
incentive to apply these talents in a lawful manner upon 
release to make his victim whole").

                               III. CONCLUSION


     For the foregoing reasons, we conclude that the district 
court correctly (1) enhanced Bapack's sentence pursuant to 
section 3B1.1(c) of the Guidelines, (2) cumulatively enhanced 
her sentence pursuant to sections 3B1.1(c) and 2F1.1(b)(2)(A) 
of the Guidelines and (3) ordered her to pay restitution in the 
amount of $62,294.50.  Accordingly, Pauline Ngo Bapack's 
sentence is

Affirmed.


__________
     15 The Report noted as to Bapack's ability to satisfy a future (and 
joint) restitution obligation:  (1) she has made a good living since 
seeking asylum in this country in 1984;  (2) she is trained as a 
nurse;  (3) she has a long and stable history of successful employ-
ment as a nurse;  and (4) she possesses entrepreneurial talent as 
evidenced by her ability to obtain the necessary certifications for, 
and launch, her own home health care agency.  See Report pp 44-
57.