https://www.cnbc.com/2021/01/20/anthony-levandowski-pardoned-after-stealing-trade-secrets-from-google.html says:

  • Anthony Levandowski pardoned after stealing trade secrets from Google
  • In August, Levandowski was sentenced to 18 months in prison for stealing trade secrets.
  • In March, Levandowski declared bankruptcy after a court said he had to pay $179 million to Google over his split with Waymo.

Do US presidential pardons include the cancellation of financial punishments?

  • 4
    wouldn't the (re)payment to Google be a civil process, separate from the criminal process about the stealing of trade secrets and only the latter a pardonable federal crime? Commented Jan 20, 2021 at 21:36
  • 2
    @HagenvonEitzen financial restitution may also be required as part of a criminal sentence.
    – phoog
    Commented Jan 21, 2021 at 3:13

4 Answers 4



Presidential pardons only deal with breaches of Federal law. So, if the punishment is a fine then that penalty is waived. However, if the fine is punishment for breach of state law, the pardon does not touch it - he would need a pardon from the relevant state Governor(s).


Anthony Levandowski is not being punished with a fine, he was punished with a jail term.

What he owes Google is damages for breach of contract or a tort, both civil matters and almost certainly under California law, not a punishment for an offence. This is not something he can be pardoned for by a President (if under Federal law which is unlikely) or a Governor (if under state law).

His actions constituted both an offence against the state, which can be pardoned, and caused damage to another person (Google) which can’t. He owes this money as a debt just as if he had bought something from them or borrowed money from them.

  • Here it is stated that pardons extend to restitutions: " A full and unconditional presidential pardon extends to the remission of restitution ordered by a court pursuant to 18 U.S.C. з 3551(b)-(c) as a "sanction" authorized in addition to imprisonment, probation, or a fine until such time as the restitution award is paid to the victim." Commented Jan 20, 2021 at 21:53
  • 23
    @raffaem Levandowski was only ordered to pay $756,499.22 in restitution as part of his sentence for stealing trade secrets. The vast majority of the $179M he owes Google was awarded by an arbitration panel and confirmed by a California court, and isn't part of any criminal sentence and so isn't forgiven by Trump's pardon. justice.gov/usao-ndca/pr/… washingtonpost.com/technology/2020/03/04/levandowski-bankrupt
    – Ross Ridge
    Commented Jan 21, 2021 at 0:54
  • From what I've read, pardons do not apply to civil judgments. Anticipation of a possible pardon will lead some attorneys to assess civil fines, in addition to any criminal penalties.
    – rcgldr
    Commented Jan 22, 2021 at 2:19
  • I guess the only one who could "pardon" that debt is Google (i.e. the creditor). Commented Jan 23, 2021 at 19:30

According to the DoJ,

A commutation may include remission (release) of the financial obligations that are imposed as part of a sentence, such as payment of a fine or restitution. A remission applies only to the part of the financial obligation that has not already been paid.

The Brookings Institute offers a slightly different (more detailed) opinion.

If a monetary fine or contraband cash has been transferred to the Treasury, a pardon conveys no right to a refund, nor does the person pardoned have a right to reacquire property or the equivalent in cash from a legitimate purchaser of his seized assets or from an informant who was rewarded with cash taken from the pardoned person before he was pardoned. If, however, a person is pardoned before title to money or property has fully vested in a person or entity, the money will be refunded unless the conditions of the pardon preclude this.



The pardon power is granted by Article 2 of US Constitution:

The President ... shall have Power to grant Reprieves and Pardons for Offenses against the United States, except in Cases of impeachment.

The pardon power

include the power to grant pardons, conditional pardons, commutations of sentence, conditional commutations of sentence, remissions of fines and forfeitures, respites and amnesties

As you said, Anthony Levandowski was granted a pardon (not, for instance, a commutation)

The statement released by the White House (now seems deleted from the White House website, but can be found on archive.org here) says that (bold is mine):

Anthony Levandowski – President Trump granted a full pardon to Anthony Levandowski. This pardon is strongly supported by James Ramsey, Peter Thiel, Miles Ehrlich, Amy Craig, Michael Ovitz, Palmer Luckey, Ryan Petersen, Ken Goldberg, Mike Jensen, Nate Schimmel, Trae Stephens, Blake Masters, and James Proud, among others. Mr. Levandowski is an American entrepreneur who led Google’s efforts to create self-driving technology. Mr. Levandowski pled guilty to a single criminal count arising from civil litigation. Notably, his sentencing judge called him a “brilliant, groundbreaking engineer that our country needs.” Mr. Levandowski has paid a significant price for his actions and plans to devote his talents to advance the public good.

The official documents granting pardons are generally available here, but this website was last updated "December 24, 2020", so (I assume) it will take sometime before the pardon document related to Anthony Levandowski is available.

If you scroll, the President generally grants "full and unconditional pardons".

In general, as stated here:

a pardon is a full forgiveness of punishment

And, as stated here:

A full and unconditional presidential pardon extends to the remission of restitution ordered by a court pursuant to 18 U.S.C. з 3551(b)-(c) as a "sanction" authorized in addition to imprisonment, probation, or a fine until such time as the restitution award is paid to the victim.

So it looks like the restitution was forgiven to.

  • 5
    But remember that the restitution is tiny compared to the damages he has to pay, and which doesn’t go away.
    – gnasher729
    Commented Jan 21, 2021 at 16:07

Not a pardon, but when Trump granted a commutation to former Detroit mayor Kwame Kilpatrick, the order left intact his $4.7 million federal restitution obligation, and his 3-year term of supervised release.

From the Detroit Free Press article.

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