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 and Vicky Child Pornography Victim Restitution Improvement Act was introduced.
Paroline v. U.S. | |
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Argued January 22, 2014 Decided April 23, 2014 | |
Full case name | Doyle Randall Paroline, Petitioner v. United States, et al. |
Docket no. | 12-8561 |
Citations | 572 U.S. 434 (more) 134 S. Ct. 1710; 188 L. Ed. 2d 714 |
Case history | |
Prior | 701 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 | |
| |
Case opinions | |
Majority | Kennedy, joined by Ginsburg, Breyer, Alito, Kagan |
Dissent | Roberts, joined by Scalia, Thomas |
Dissent | Sotomayor |
Laws applied | |
18 U.S.C. § 2259 |
References
- In re Amy Unknown, 701 F.3d 749 (5th Cir. 2012).
- Paroline v. United States, 572 U.S. 434 (2014).
- Cassell, Paul (2014-04-24). "A legislative fix for Paroline?". The Washington Post. Retrieved 2017-04-26.
External links
- Text of Paroline v. United States, 572 U.S. 434 (2014) is available from: Cornell Justia Oyez (oral argument audio) Supreme Court (slip opinion)
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