“While Congress could and should have made determination of the amount to which a victim is entitled a simple matter, it regrettably did not.” With these words, the influential Ninth Circuit Court of Appeals—which decides the law in fifteen federal ...
On April 23, 2014, the United States Supreme Court issued a much-anticipated decision concerning federal criminal restitution for child pornography victims. The case, Paroline v. United States, 134 S. Ct. 1710, 188 L. Ed. 2d 714 (2014), attracted 14 amicus ...
United States District Court Judge John J. McConnell, Jr., in one of the first reported cases since the Supreme Court’s April 23, 2014 decision in United States v. Paroline, illustrates the growing frustration within the federal courts which are struggling to ...
Last week, another federal district court struggling to implement the Supreme Court’s decision in Paoline admonished Congress to fix the law. In a child pornography restitution case, Chief Judge Anne L. Aiken of the United States District Court for the ...
On June 5, 2014, the Sixth Circuit Court of Appeals—in the first federal circuit court ruling since the United States Supreme Court issued its decision in Paroline in April—held that a child pornography defendant is not liable for a victim’s ...