PAROLINE v. UNITED STATES

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Case Basics
Docket No. 
12-8561
Petitioner 
Doyle Randall Paroline
Respondent 
United States and Amy Unknown
Term:
Facts of the Case 

Doyle R. Paroline pled guilty to possession of 150-300 images of child pornography. Included among those files on his computer were two photographs of Amy Unknown, a victim of child pornography. He was sentenced to 24 months of incarceration followed by release under supervision. Under a federal statute that mandates full restitution to victims of child pornography by those convicted of creating, distributing or possessing such material, the Government and Amy sought restitution in the amount of nearly $3.4 million. The district court denied restitution and held that the statute required the Government to prove that Paroline’s possession of the images was the proximate cause of the injuries for which restitution was sought. The U.S. Court of Appeals for the Fifth Circuit reversed and held that Paroline was responsible for restitution for all the victim’s losses even if his criminal acts occurred after the victim’s losses.

Question 

To recover restitution, must either the government or the victim establish a causal relationship between the defendant's conduct and the victim's harm or damages?

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PAROLINE v. UNITED STATES. The Oyez Project at IIT Chicago-Kent College of Law. 23 April 2014. <http://www.oyez.org/cases/2010-2019/2013/2013_12_8561>.
PAROLINE v. UNITED STATES, The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2013/2013_12_8561 (last visited April 23, 2014).
"PAROLINE v. UNITED STATES," The Oyez Project at IIT Chicago-Kent College of Law, accessed April 23, 2014, http://www.oyez.org/cases/2010-2019/2013/2013_12_8561.