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Paroline v. United States: The Decision

Commentaries/Reactions

The Supreme Court promises child pornography victims full restitution "someday." How long is that?
Paul Cassell,  The Washington Post   APR 23

The crime victim's reaction to today's Supreme Court decision
Amy, the victim in today's Supreme Court case, gives her reaction to the Court's split-the-difference ruling.
Paul Cassell,  The Washington Post   APR 23

Supreme Court Decision

PAROLINE v. UNITED STATES ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT
No. 12–8561. Argued January 22, 2014—Decided April 23, 2014

701 F. 3d 749, vacated and remanded

Read the Opinion

  1. Restitution is proper under §2259 only to the extent the defendant’s offense proximately caused a victim’s losses
  2. Applying the statute’s causation requirements in this case, victims should be compensated and defendants should be held to account for the impact of their conduct on those victims, but defendants should only be made liable for the consequences and gravity of their own conduct, not the conduct of others.
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