The Ninth Circuit issued an interesting decision discussing the application of the federal Mandatory Victims Restitution Act (18 U.S.C. § 3663A) to the cleanup of a methamphetamine laboratory 10/2/07 in United States v. Brock-Davis, No. 06-30565.
Without going into tedious detail, the appellate panel concludes that the MVRA does apply to damage done
However, it was inappropriate to charge Brock-Davis for “lost income” resulting from the inability to rent the hotel room because the hotel had plenty of available
(Below: This hotel, in Kalispell, Montana (which I won’t name so as to avoid giving it bad Google voodoo, though you can see the name in the picture) is described on tripadvisor.com as having rooms that are “older, but clean.” That must be because of the exciting methamphetamine cleanup that took place in this case. Previously, however, Room 107 contained “an ice bucket with dark purple stains both on the bottom and floating in clear liquid, an empty box for a microwave oven, a white powdery substance, and other items indicative of a meth lab.”)