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.

[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.

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