Should the Court extend the rule of Apprendi to the award of criminal restitution?

QUESTION PRESENTED This Court held in Apprendi v. New Jersey, 530 U.S. 466, 490 (2000), that “{o]ther than the fact of a prior conviction, any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury, and proved beyond a reasonable doubt.” In Southern Union Co. v. United States, 567 U.S. 343 (2012), the Court extended the rule of Apprendi to the imposition of criminal fines. Nevertheless, the federal courts of appeals have persisted in holding that the rule of Apprendi does not apply to criminal restitution. The question presented is: Should the Court extend the rule of Apprendi to the award of criminal restitution?