In a precedent-setting move, federal courts have begun ordering the return of restitution payments to January 6 defendants whose convictions were vacated following presidential pardons.
On August 29, 2025, U.S. District Judge John Bates authorized a $2,270 refund to Yvonne St. Cyr, a prominent January 6 defendant. St. Cyr had been convicted of obstructing law enforcement but was granted a full presidential pardon. Judge Bates ruled that because her case was still pending appeal when the pardon was issued, her conviction was effectively erased in the eyes of the law, entitling her to a return of the funds.
Following St. Cyr’s case, the trend has widened. On December 3, 2025, Chief U.S. District Judge James Boasberg ordered full refunds for defendants Cynthia Ballenger and Christopher Price. Like St. Cyr, they had appeals pending when they received clemency. Boasberg noted that under these specific legal circumstances, the government is obligated to return fines and restitution, reversing his own earlier decision to deny such requests.
The key factor driving these refunds is the timing of the pardon. Courts have determined that if a defendant’s conviction was not yet “final” (meaning it was still being appealed) when the pardon was issued, the pardon wipes the slate clean completely. This legal status treats the conviction as if it never happened, removing the government’s legal basis to keep the restitution money originally collected for damages to the Capitol.
The decision to use taxpayer money to reimburse rioters has sparked significant controversy. Senate Democrats have sharply criticized the Justice Department for not opposing these requests more vigorously, arguing that the costs of repairing the Capitol—estimated at nearly $3 million—should remain the responsibility of those who caused the damage, regardless of their pardon status.