It overturned a notorious 5-to-4 Supreme Court decision from 2007 that had denied Ms. Ledbetter restitution for years in which her employer, the Goodyear Tire and Rubber Company, had paid her less than her male colleagues.
The man, Michael Scanlon, was sentenced two weeks ago to serve 20 months in prison and pay $20 million in restitution for a scheme in which he and Mr. Abramoff defrauded Indian tribe clients.
It was being sold by the Leopold museum to pay for another Schiele, "Portrait of Wally" (1912), which was seized by the Nazis and was later at the center of a restitution case, settled last year, in which the Vienna museum agreed to pay the heirs of the original owner, Lea Bondi Jaray, a Jewish gallerist in Vienna, $19 million.
Elazar Barkan, the chairman of the cultural studies department at Claremont Graduate University in California, contends that since the end of the cold war, the West in particular has entered a neo-Enlightenment period of political morality in which restitution increasingly plays a leading role.
Wade Rathke said the organization had signed a restitution agreement with his brother in which his family agreed to repay the amount embezzled in exchange for confidentiality.
As the first step in what he expects will become a broad investigation, Mr. Spitzer announced this week that Edward Stern and his hedge fund, Canary Capital Partners, had agreed to pay $40 million in fines and restitution to settle a case in which they admitted no wrongdoing.
In many cases, victims cannot identify the perpetrators, in which case restitution becomes impossible.
In February, the agency announced that Capital One would pay $775,000 in restitution, which West Virginia said addressed only one of seven issues it had raised.
Mr. Spitzer pushed for $6 million in restitution, which the State Banking Department raised to $7.25 million, plus 525,000 shares of Delta stock it valued at nearly $5 million.
