Federal Judge Orders First Restitution Refund for Jan. 6 Defendant Following Pardon

August 29, 2025 - WASHINGTON, D.C. - A federal judge has authorized the refund of court-ordered restitution paid by the first January 6 defendant to benefit from President Trump’s mass pardon, marking a significant legal development in the aftermath of the Capitol breach.

U.S. District Judge John D. Bates, appointed by President George W. Bush, reluctantly approved a $2,270 refund to Yvonne St. Cyr, who had paid fines and restitution after her March 2023 conviction for impeding police during the Capitol riot. Her felony conviction was vacated and dismissed following Trump’s pardon of all January 6 participants, prompting her request for a return of the funds she had already remitted.

“Sometimes a judge is called upon to do what the law requires, even if it may seem at odds with what justice or one’s initial instincts might warrant,” Bates wrote in his opinion. “This is one such occasion.” He emphasized that, under the law, vacatur of a conviction gives rise to a presumption of innocence and strips the government of any right to retain funds paid under the now-vacated judgment.

St. Cyr, who insisted at sentencing that she “did the right thing” while egging on fellow rioters at the Capitol’s Lower West Terrace tunnel, remains unrepentant. Bates noted that neither the D.C. Circuit nor his court has declared her factually innocent; however, the legal effect of the pardon “deems [the funds] always hers,” he wrote.

Several other judges have rebuffed similar refund petitions, arguing that once restitution and fines are paid into the U.S. Treasury, only Congress can authorize their return. Bates diverged from that consensus, finding inherent judicial authority to correct the financial judgment after vacatur.

This ruling represents the first successful restitution refund among January 6 defendants pardoned by President Trump and may open the door for other pardoned individuals to seek similar monetary relief.