McIntosh v. United States

Summary

The Supreme Court held that a district court’s failure to enter a preliminary forfeiture order before sentencing under Fed. R. Crim. P. 32.2(b)(2)(B) does not strip the court of authority to order forfeiture at sentencing, and such non‑compliance is reviewed under harmless‑error principles. The Court classified the rule as a “time‑related directive,” not a mandatory claim‑processing rule, and affirmed the Second Circuit’s judgment.