Feb. 28, 2023 – People v. Ung (6th Dist., H049359)

Defendant pled no contest to stealing various cryptocurrencies from multiple victims between June and December 2018. In September 2021, by which time the cryptocurrencies had increased in value from about $1.56 million to about $15.9 million, the trial court ordered defendant to make restitution by transferring cryptocurrencies to the victims in the same kinds and amounts he stole from them. The Court of Appeal affirms the order, rejecting defendant’s arguments that it provided the victims with an undue windfall and violated his due process rights by failing to give him adequate notice of his actual liability.