U.S. District Judge James Boasberg reversed himself and ordered full refunds for two Jan. 6 defendants pardoned by President Donald Trump, saying a vacated conviction can erase the government’s claim to money collected because of that conviction.
Judge Boasberg surprised observers by flipping his earlier decision and directing that Cynthia Ballenger and Christopher Price receive every penny they paid in restitution and fines tied to their misdemeanor convictions from the Jan. 6, 2021, Capitol events. The ruling came down Wednesday, and it directly undoes financial penalties assessed after those misdemeanor convictions. For ordinary Americans, refunding those payments is a concrete outcome, not just legal theory.
Ballenger and Price had been convicted on misdemeanor charges tied to the Capitol unrest and were hit with hundreds of dollars in fees and restitution as part of their sentences. Those sums mattered to them and became the focus of renewed court fights after the presidential pardon. The refunds are limited to what was collected because of those specific convictions.
Back in July, Judge Boasberg rejected their bid for refunds, relying on precedent that a pardon does not necessarily allow someone to reclaim money paid in connection with a conviction. That ruling left the defendants with little apparent recourse and underscored how narrow the law can feel when someone asks for relief. The initial denial sparked criticism from those who argue pardons should carry practical effects.
This year changed the trajectory in a big way. President Trump issued pardons for roughly 1,500 Jan. 6 defendants, including Ballenger and Price, while their appeals were still pending before the D.C. Circuit. The timing effectively placed their convictions in a different legal posture and reopened questions about whether refunds should follow. The presidential action shifted the legal landscape from denial to reconsideration.
Once the pardons took effect, the D.C. Circuit vacated the defendants’ convictions, which in turn mooted the pending appeals and prompted Ballenger and Price to press the district court again for money back. A vacatur is not a mere technicality here; it removes the underlying judgment that justified the payments. That legal change forced Judge Boasberg to revisit the refund question on fresh footing.
In his new ruling, Boasberg made a stark, plain statement: “Having viewed the question afresh, the court now agrees with the defendants,” he stated on Wednesday. The judge then explained the constitutional and equitable logic supporting repayment. His language framed the issue less as sympathy and more as correcting a practical consequence of vacated convictions.
Boasberg spelled out the key legal point plainly, writing, “So even if defendants’ pardon does not entitle them to refunds, the resulting vacatur of their convictions might,” and he emphasized that a vacated conviction “wipes the slate clean.” That exact phrasing anchors the decision to a specific legal effect: removing a conviction can undo the government’s authority to hold onto money extracted because of it. The quote will likely get cited in similar requests going forward.
The judge also addressed whether the court even had authority to order repayments and concluded that if the court could require payments in the first place, it could unwind them when circumstances change. He dismissed sovereign immunity as a barrier to correcting the record and returning funds. The practical effect is to put the judiciary in a position to correct financial outcomes tied to vacated convictions.
Supporters of the pardons hailed the decision as a narrow but meaningful check on aggressive enforcement, arguing that returning money wrongfully tied to convictions is the right call. Opponents pushed back hard, with critics pointing to the wider consequences for the Capitol and for accountability. The late Rep. Gerald Connolly, in a pointed letter, argued that Trump’s pardons let Jan. 6 participants “off the hook” for damages estimated at a staggering $2.7 billion to the U.S. Capitol.
That criticism frames the political stakes: accountability and compensation on one side, clemency and legal nullification on the other. From a Republican perspective, pardons are a legitimate use of executive power and can correct overreach or disproportionate sentencing, and this refund ruling simply follows the law where a conviction no longer stands. The decision emphasizes that legal nullification should carry practical consequences, not just symbolism.
Practically speaking, Ballenger and Price will see money returned and will avoid the long tail of penalties tied to those convictions. For courts and prosecutors, the ruling signals that vacaturs can have ripple effects beyond sentences, including financial unwinding. The Boasberg opinion will be watched closely by other defendants and by attorneys weighing whether to push for similar relief after vacatur or pardon.
Whether you cheer the outcome or complain about its political context, the ruling establishes a clear rule for this narrow set of cases: when a conviction is wiped away, the legal basis for financial penalties can evaporate with it. That principle will likely shape follow-on litigation and how prosecutors approach cases that might later be vacated or pardoned.
