Restitution for victim losses
Doyle Randall Paroline v. United States
In brief
The Court wiped out the Fifth Circuit's judgment and sent the case back, limiting restitution to losses sufficiently caused by Paroline's offense.
- Where it stands
- Decided
Decided 5-4 · April 23, 2014 · Opinion by Justice Kennedy
- What it’s about
- Doyle Paroline challenged whether he could be ordered to pay restitution for a victim’s losses without proof that his possession of her images caused them.
- Who it affects
- Under this law, victims can recover from a defendant only for losses sufficiently caused by that defendant's offense.
Summary: written with AI from the case record.
What it's about
The Supreme Court wiped out the Fifth Circuit’s judgment and sent the case back (vacated and remanded), deciding that restitution may cover only losses sufficiently connected to Paroline’s offense (proximately caused by it).
The opinions identify the victim as Amy and describe Paroline's offense as possessing two images of her.
Federal law requires judges to order restitution in child-pornography cases, including possession cases.
Question presented
To recover restitution, must either the government or the victim establish a causal relationship between the defendant's conduct and the victim's harm or damages?
What the Court decided
Holding
Restitution is proper under §2259 only to the extent the defendant’s offense proximately caused a victim’s losses. This provision has a broad restitutionary purpose, stating that a district court “shall order restitution for any offense” under Chapter 110 of Title 18, such as Paroline’s possession offense; requiring district courts to order defendants “to pay the victim... the full amount of the victim’s losses as determined by the court,” §2259(b)(1); and expressly making “is - suance of a restitution order... mandatory,” §2259(b)(4)(A). The Government has the “burden of demonstrating the amount of the [victim’s] loss.” §3664(e).
- Result
- Vacated
The Court's reasoning
The Court read the law to limit restitution to losses sufficiently caused by the defendant's crime (proximate cause). It also said the law makes restitution mandatory and requires the government to show the amount of the victim's loss.
The vote
From the opinions
“And arbitrary is not good enough for the criminal law.”
What's next
The Fifth Circuit must reconsider the restitution award using the Court's causation rule.
Documents
Opinions
Docket activity
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AI analysis generated: Case Briefing
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Opinion added: Paroline
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.