McIntosh v. United States:  Failure to comply with Rule 32 requiring preliminary order of forfeiture before sentencing does not bar forfeiture

By Greg Mermelstein, Deputy Director & General Counsel, Missouri Public Defender            Even though Rule 32.2 requires a district court to enter a preliminary order of forfeiture before sentencing, failure to do so does not bar the court from ordering forfeiture, the U.S. Supreme Court held April 17 in McIntosh v. United States.             Federal […]