Fifth Circuit: USA v. Christian Winchel

Appeals waiver did not bar appeal of restitution, as restitution in excess of proximately caused harms exceeds the statutory maximum punishment.  Sentencing court must establish statutory proximate causation for losses before imposing restitution, else, plain error.

http://www.ca5.uscourts.gov/opinions/pub/16/16-11208-CR0.pdf