Supreme Court of the United States · Official docket →
Michael Little v. United States
Paid petition · United States Court of Appeals for the Second Circuit, No. 24-2048 · judgment May 8, 2026
(petition-stage, structural)
Well below the 4.1% base rate: the model weights this down for a self-represented petitioner.
Questions presented
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Whether a writ of error coram nobis is available to challenge a criminal restitution order after the petitioner’s sentence has been fully served, an issue this Court has not resolved and on which the courts of appeals are divided.
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Whether 26 U.S.C. § 6201(a)(4)(A) authorizes the Internal Revenue Service to assess and collect criminal restitution for a tax-related offense under Title 18 as an avenue independent of the sentencing court’s restitution order — and, if so, whether a restitution order calculated without accounting for that independent assessment authority may result in duplicative recovery for the same tax loss, in light of the Seventh Circuit’s intervening decision in Daugerdas v. Commissioner of Internal Revenue, No. 25-1055 (7th Cir. Mar. 30, 2026), which conflicts with the premise underlying the decision below.
Counsel of record
For petitioner
Michael Little
For respondent
D. John Sauer
Solicitor General
Case
Subject area
Criminal Procedure (estimated from the questions presented, in the Supreme Court Database’s categories)
Conference history
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Proceedings
- Oct 05 2026Petition for a writ of certiorari filed. (Response due November 16, 2026)