## Facts

- A child victim (“Amy”) was sexually abused by her uncle, who photographed the abuse and the images later circulated online.
- Doyle Randall Paroline pleaded guilty in federal court to possessing 150–300 child-pornography images, including two images depicting Amy.
- Amy sought mandatory restitution under 18 U.S.C. § 2259 for losses totaling roughly $3 million in lost income and $500,000 in future treatment and counseling.
- The district court denied restitution, finding Amy did not show Paroline’s possession of two images proximately caused her claimed losses.
- The Fifth Circuit (en banc) reversed, holding § 2259 did not require proximate cause and that each possessor could be liable for the victim’s entire losses.
- The Supreme Court granted review to resolve how causation and amount should be determined when many offenders collectively contribute to a victim’s losses.

## Issues

1. Whether 18 U.S.C. § 2259 requires proof that the defendant’s offense proximately caused the victim’s losses.
2. If proximate cause is required, how a court should determine restitution for a defendant who possessed images when the victim’s losses result from widespread circulation by many offenders.

## Decision

- The Supreme Court reversed the Fifth Circuit and remanded.
- The Court held that restitution under § 2259 is proper only to the extent the defendant’s conduct was a proximate cause of the victim’s losses.
- The Court rejected a rule making each possessor automatically liable for the victim’s full losses.
- The Court also rejected a strict but-for causation approach that would commonly result in no restitution in possession-only cases.
- On remand, the district court was instructed to award restitution reflecting Paroline’s relative role in the causal process underlying Amy’s general losses.

## Legal Principles

- Section 2259 incorporates a proximate-cause requirement; restitution must reflect the defendant’s causal relationship to the victim’s losses.
- In child-pornography possession cases, the victim’s losses may be caused by the combined conduct of many offenders; individual offenders can be a proximate cause of some portion of those losses even if no single offender is the but-for cause of the total harm.
- Restitution must be set in an amount that is reasonable and tied to the defendant’s relative contribution, not the full consequences of other offenders’ conduct.
- In estimating an appropriate amount, district courts may consider practical factors such as: the number of other defendants held responsible to date; expected future convicted offenders; estimates of broader offender participation; whether the defendant distributed or reproduced images; any connection to production; and the number of the victim’s images the defendant possessed.

## Conclusion

The Court held that § 2259 restitution requires proximate cause and must be calibrated to a possessor-defendant’s relative contribution to the victim’s losses, using a practical, fact-based approximation rather than imposing either zero restitution or full-loss liability.


Paroline v. United States, 572 U.S. 434 (2014)