After mother was convicted of various charges based, in part, on failure to pay a foreign citizen whom she arranged to immigrate based on a fraudulently obtained visa, the court ordered her to pay the foreign citizen restitution based on the value of the services performed. In the restitution order, the court ordered mother to use child support moneys owed by the children’s father to pay restitution. The Ninth Circuit reversed this portion of the order. Even though child support is payable to the custodial parent, the duty to pay support runs to the child; the parent to whom the support is paid is merely a conduit for the payment. U.S. v. Dann (9th Cir.; July 22, 2011) 652 F.3d 1160.
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