Paroline v. United States

Paroline v. United States, 572 U.S. 434 (2014), is a case in which the United States Supreme Court ruled that to recover restitution under 18 U.S.C. § 2259, the government or the victim must establish a causal relationship between the defendant's conduct and the victim's harm or damages. The decision vacated the appellate court decision,[1] and remanded it.[2] A legislative fix was subsequently proposed by Marci Hamilton.[3] Ultimately, the Amy, Vicky, and Andy Child Pornography Victim Assistance Act of 2018 was introduced in response.

Paroline v. U.S.
Argued January 22, 2014
Decided April 23, 2014
Full case nameDoyle Randall Paroline, Petitioner v. United States, et al.
Docket no.12-8561
Citations572 U.S. 434 (more)
134 S. Ct. 1710; 188 L. Ed. 2d 714
Case history
Prior701 F.3d 749 (5th Cir. 2012); cert. granted, 570 U.S. 931 (2013).
Holding
To recover restitution, the government or the victim must establish a causal relationship between the defendant's conduct and the victim's harm or damages.
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinions
MajorityKennedy, joined by Ginsburg, Breyer, Alito, Kagan
DissentRoberts, joined by Scalia, Thomas
DissentSotomayor
Laws applied
18 U.S.C. § 2259

References

  1. In re Amy Unknown, 701 F.3d 749 (5th Cir. 2012).
  2. Paroline v. United States, 572 U.S. 434 (2014).
  3. Cassell, Paul (April 24, 2014). "A legislative fix for Paroline?". The Washington Post. Retrieved April 26, 2017.


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