KOZINSKI, Circuit Judge.
We are called on to decide if debarment from participation in government programs is punishment for purposes of the double jeopardy clause.
Randy Borjesson preyed on innocent homeowners. He offered to assume their HUD- or VA-insured mortgages; in exchange, they paid him rent. Borjesson spent the rent money but didn't make the mortgage payments, causing 33 defaults. After his crimes were discovered, he tried to evade the authorities...
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