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Case Summary

United States v. Quarrell

United States v. Quarrell, No. 00-cr-322, (unpublished) (D. N.M. 2001); aff'd and remanded for re-sentencing, 310 F.3d 664 (10th Cir. 2002); re-sentenced, No. 00-cr-322, (D. N.M. 2003).

See also: United States v. Lynch and United States v. Shumway.


In a case involving damage to an archaeological site, the Tenth Circuit held that in a prosecution for an alleged violation of the Archaeological Resources Protection Act (ARPA), the Government is not required to prove that the defendants knew they were excavating on public land.  The court also held that the defendants were only liable to pay restitution for the repair and restoration of the site, but not for any loss of “archaeological value” they may have caused.      

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