Doyle Randall Paroline, Petitioner v. United States

Summary

The Court held that restitution under 18 U.S.C. §2259 is proper only to the extent the defendant's offense proximately caused the victim's losses, reading the catchall category's 'proximate result' limitation across all six enumerated loss categories. Because an anonymous possessor's but-for share of a victim's losses from the Internet-wide trade in her images cannot be isolated, the Court rejected both the strict but-for showing the District Court demanded and the victim's aggregate-causation theory that would make each possessor liable for her entire losses, and instead instructed district courts to order restitution in an amount that comports with the defendant's relative role in the causal process underlying the victim's general losses — a reasonable, circumscribed amount that is neither token nor severe. The Fifth Circuit's en banc judgment, which had imposed full-loss liability without a proximate-cause limit, was vacated and the case remanded. Chief Justice Roberts, joined by Justices Scalia and Thomas, dissented on the ground that the statute as written permits no recovery here, and Justice Sotomayor dissented because she would enforce §2259's 'full amount' command through aggregate causation and joint-and-several liability moderated by periodic payment schedules.