Congress’ intent to authorize an award of restitution only for the loss caused by the specific conduct that is the basis of the offense of conviction.” Id. at 413,110 S.Ct. 1979. In 1990, Congress amended the VWPA’s definition of “victim” to mean: a person directly and proximately harmed as a result of the commission of an offense for which restitution may be ordered including, in the case of an offense that involves as an element a scheme, conspiracy, or pattern of criminal activity, any person directly harmed by the defendant’s criminal conduct in the course of the scheme, conspiracy, or pattern. 18 U.S.C. § 3663(a)(2). The MVRA was enacted in 1996 and contains an identical definition of victim. 18 U.S.C. § 3663A(a)(2). Since the change in definition, courts have 141 (3d Cir.1999) (<HOLDING>). While the language expands what it is that
holding that the ex post facto clause prohibited retroactive application of the mvra because before the mvra became effective the victim and witness protection act authorized but did not compel district courts to order restitution holding that an award of restitution is only for the loss caused by the specific conduct that is the basis of the offense of conviction holding that the conduct underlying the offense of conviction thus stakes out the boundaries of the restitutionary authority under the mvra holding that the relevant question in imposing restitution under the mvra is whether the loss is caused by the specific conduct that is the basis of the offense of conviction holding that court cannot order restitution under the mvra to persons who are not victims of the offenses for which the defendant was convicted