UNITED STATES OF AMERICA, — v. RANDY LEE VANHORN, —

Randy Lee Vanhorn was convicted of mail fraud and money laundering. The district court 1 imposed a sentence of 71 months in prison and $44,000 in victim restitution. Vanhorn appealed, and we remanded for determination of a restitution payment schedule, which the district court then set at 50% of the funds available to Vanhorn while he is in prison. Vanhorn again appealed, and we affirmed his conviction and sentence. United States v. Vanhorn, 344 F.3d 729 (8th Cir.2003).

The Mandatory Victims Restitution Act provides that, upon notice “of any material change in the defendant’s economic…