Paroline v. United States
United States Supreme Court
134 S. Ct. 1710 (2014)
- Written by Rich Walter, JD
Facts
Following Doyle Randall Paroline's (defendant's) conviction for possessing pornographic images of child sexual abuse, the United States government (plaintiff) sought $3.4 million in restitution from Paroline on behalf of "Amy," one of the children depicted in the images. Amy, by then an adult, claimed that she’d sustained damages due to the traumatization she suffered from knowing that the images were in worldwide Internet circulation and available to thousands of people like Paroline. The government based its claim on 18 U.S.C. § 2259, a provision in the Violence Against Women Act of 1994 that Congress enacted to compensate a victim like Amy after a crime like Paroline's, if her damages were the proximate result of, and would not have occurred but for, the crime. The government admitted that none of Amy's damages flowed from any specific knowledge she had about Paroline or his possession of her images. A federal district court dismissed the claim, ruling that the government failed to prove that Paroline's offense was the proximate cause of Amy's damages. An appellate court upheld the district court's ruling, and the government appealed to the United States Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Kennedy, J.)
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