United States v. Padilla
CourtCourt of Appeals for the Fifth Circuit
Date FiledSeptember 1, 2026
Docket25-30500
StatusPublished
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Full Opinion
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United States Court of Appeals
for the Fifth Circuit
____________ United States Court of Appeals
Fifth Circuit
FILED
No. 25-30500 September 1, 2026
____________
Lyle W. Cayce
United States of America, Clerk
Plaintiff—Appellee,
versus
Luis Enrique Padilla,
Defendant—Appellant.
______________________________
Appeal from the United States District Court
for the Western District of Louisiana
USDC No. 6:24-CR-257-1
______________________________
Before King, Smith, and Ramirez, Circuit Judges.
Per Curiam:
Luis Enrique Padilla appeals an order of restitution under the
Mandatory Victims Restitution Act (MVRA), 18 U.S.C. § 3663A, following
his guilty plea conviction for misdemeanor deprivation of rights in violation
of 18 U.S.C. § 242. We AFFIRM.
I
A
Padilla is the former chief of the Sunset Police Department in Sunset,
Louisiana. While investigating a hit-and-run incident in December of 2023,
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Padilla encountered R.A. outside of the suspect’s house. R.A. “was not
aware of the hit and run” and “did not match the physical description of the
suspect.” Padilla “approached [him] in an aggressive manner and placed him
in handcuffs.” Although “R.A. was not resisting” and did not “pos[e] a
threat to himself or any officer,” Padilla “poked” him “in the chest and neck
area and began to yell at” him. “R.A. was still handcuffed” when “Padilla
warned ‘let me show you how bad I am’ and proceeded to forcefully twist
[and sprain his] left thumb and wrist.” “Padilla acknowledges and agrees that
he willfully used unreasonable force under the circumstances.”
B
Padilla was indicted for deprivation of rights under color of law in
violation of 18 U.S.C. § 242. The indictment alleged that Padilla violated
R.A.’s right “to be free from unreasonable seizures, which includes the right
to be free from a law enforcement officer’s use of unreasonable force during
an investigation and detention” when he, “without legal justification and
while R.A. was restrained in handcuffs, forcefully twisted R.A.’s thumb and
wrist in a manner intended to cause pain, which resulted in bodily injury.”
Because the indictment alleged that Padilla caused bodily injury, the § 242
violation was charged as a felony.
Padilla pleaded guilty to a superseding bill of information that charged
him with a § 242 violation without causing bodily injury, a misdemeanor. The
district court sentenced Padilla to five years of probation. The Presentence
Investigation Report (PSR), which it had adopted at sentencing, stated that
Padilla “is unable to pay a fine in either a lump sum, or monthly installments,
in addition to any restitution ordered by the [district] [c]ourt.” The district
court did not impose a fine and deferred its decision regarding restitution
until a later hearing.
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The Government sought $5,312.08 in restitution—$5,000 for twenty
one-hour therapy sessions for the victim, plus $312.08 in expenses the victim
incurred in relocating from Sunset after the incident. At the restitution
hearing, it offered a psychologist’s testimony, which the district court found
credible, that R.A. had PTSD due to Padilla’s use of force and that he both
needed and wanted treatment. Concluding that the MVRA applied because
Padilla was convicted of a crime of violence, the district court ordered Padilla
to pay $3,500 in restitution for R.A.’s therapy, but it rejected the request for
moving expenses as impermissible under the MVRA. Padilla argued that the
Government did not prove the amount of its restitution request but did not
object to application of the MVRA. He now appeals the restitution order.
II
Because Padilla did not preserve his first point of error, that the
MVRA does not apply, our review is for plain error. See United States v.
Borino, 123 F.4th 233, 245 (5th Cir. 2024). Padilla must show: (1) an “error,”
(2) “that is ‘plain,’” and (3) “that ‘affect[s] substantial rights.’” Id.
(alteration in original) (quoting Johnson v. United States, 520 U.S. 461, 466–
67 (1997)). “If all three conditions are met, an appellate court may then
exercise its discretion to notice a forfeited error, but only if (4) the error
seriously affects the fairness, integrity, or public reputation of judicial
proceedings.” Id. (quoting Johnson, 520 U.S. at 466–67).
As for Padilla’s second argument that even if the MVRA does apply,
the restitution award is erroneous, “we review the legality of the restitution
award de novo, ‘and if the award is legally permitted, we review the amount
for abuse of discretion.’” United States v. Mahmood, 820 F.3d 177, 196 (5th
Cir. 2016) (quoting United States v. Klein, 543 F.3d 206, 215 (5th Cir. 2008)).
We review factual findings for clear error. United States v. Barnes, 979 F.3d
283, 313 (5th Cir. 2020).
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III
Under the MVRA, a district court “shall order” restitution when a
defendant is convicted of “a crime of violence, as defined in section 16.” 18
U.S.C. § 3663A(a)(1), 3663A(c)(1)(A)(i). Padilla argues that the district
court plainly erred in applying the MVRA because he was not convicted of a
crime of violence under United States v. Williams, which stated that a
misdemeanor violation of 18 U.S.C. § 242 “is not a crime of violence.” 343
F.3d 423, 432 (5th Cir. 2003) (citation modified). Even if Padilla satisfied the
first three prerequisites to plain-error relief, we would decline to exercise our
discretion to correct the error because he has not carried his burden as to the
fourth.
Under the fourth prong, “[t]he Court of Appeals should correct a
plain forfeited error affecting substantial rights if the error ‘seriously affect[s]
the fairness, integrity or public reputation of judicial proceedings.’” United
States v. Olano, 507 U.S. 725, 736 (1993) (second alteration in original)
(quoting United States v. Atkinson, 297 U.S. 157, 160 (1936))). Padilla “has
the further burden to persuade the court” to correct the error. See United
States v. Vonn, 535 U.S. 55, 63 (2002).
Padilla asserts that the district court’s erroneous conclusion that he
was convicted of a crime of violence, which triggered application of the
MVRA, “by its very nature,” satisfies the fourth prong because the law
“fundamentally requires courts to comply with statutes,” and in United
States v. Hankton, 51 F.4th 578 (5th Cir. 2022), we held that an erroneous
application of the MVRA met this standard. But Hankton is materially
distinguishable. In Hankton, this court corrected an erroneous restitution
order under the MVRA. Id. at 595. There, three co-defendants were jointly
and severally liable for a $1.6 million restitution order. Id. at 594 n.6, 595.
Two argued that the restitution order was plainly erroneous because they
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were not convicted of crimes of violence, and the Government conceded the
point. Id. at 595. The third belatedly raised the issue in his reply brief, though
the error applied to him, too. Id. To avoid “compounding” the error so that
the third co-defendant would have been liable for the entire restitution
amount, and in light of the Government’s concession, this court vacated the
restitution order as to the third co-defendant, as well. Id. Even if Hankton
were not distinguishable, it would not control here because “[t]he fourth
prong is meant to be applied on a case-specific and fact-intensive basis.” See
Puckett v. United States, 556 U.S. 129, 142 (2009).
We agree with Padilla that the law “fundamentally requires courts to
comply with statutes.” But even if the district court’s restitution order was
outside of the MVRA, that alone cannot trigger our discretion. If a defendant
need only show statutory non-compliance to obtain plain-error relief,
correction would be automatic in every case involving statutory error. Our
precedent makes clear that plain-error correction “is not automatic,” United
States v. Brown, 826 F.3d 835, 840 (5th Cir. 2016), and “[r]eversing a district
court for plain error should be ‘rare,’” id. at 841 (quoting United States v.
Escalante-Reyes, 689 F.3d 415, 426 (5th Cir. 2012) (Smith, J. dissenting)).
And in the punishment context, “[w]e have consistently held that it is not
necessary to correct an error if” the record is “sufficient” to show that “the
incorrect sentence was . . . fair.” Id.
Padilla concedes that, even if the MVRA does not apply, the district
court could have imposed discretionary restitution under 18 U.S.C.
§ 3663(a)(1)(A). The district court considered the whole of the
psychologist’s testimony during the restitution hearing, expressly noting that
its credibility was supported by the emotional distress it had “certainly”
observed during R.A.’s oral victim impact statement at the sentencing
hearing. It ordered Padilla to pay for R.A.’s therapy in an amount quantified
by the psychologist’s testimony to remedy the injury he inflicted on R.A.
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while abusing his position as the sheriff, which it had identified at sentencing
as “a larger issue” that “undermin[ed the] public’s confidence in law
enforcement.” See infra Section IV. On these facts, Padilla has not met his
burden as to the fourth prong.
IV
Padilla next argues that, even if the MVRA applies, the restitution
order for future psychological care is unsupported by both law and adequate
proof. Even if the MVRA does not apply to this case, we nevertheless
disagree with Padilla.
A
Padilla asserts that the MVRA does not allow restitution for future
psychological care. Even if he did not forfeit this issue by failing to assert it
below, see Olano, 507 U.S. at 731, this court has already held that the MVRA
permits restitution for “future psychological care,” United States v. Serrata,
679 F. App’x 337, 340 (5th Cir. 2017) (per curiam) (unpublished). We see no
reason to depart from Serrata.
B
Finally, Padilla contends that the Government failed to prove that the
victim genuinely sought restitution for psychological treatment, and that
Padilla caused the need for that treatment. We disagree.
Padilla asks us to doubt the district court’s credibility determinations.
But we “give credence to . . . credibility choices and findings of
fact . . . unless they are clearly erroneous.” United States v. Bass, 10 F.3d 256,
258 (5th Cir. 1993). The Government’s psychologist testified that the victim
suffered from PTSD because of Padilla’s use of force, needed psychological
care, and wanted treatment. He explained his reasoning, and the district
court found all of his testimony “credible.” “We will not second guess” that
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reasoning because Padilla has shown no clear error. See United States v.
Garza, 118 F.3d 278, 283 (5th Cir. 1997).
V
The judgment of the district court is AFFIRMED.
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