United States v. Ahlazshuna Dillard, No. 17-4417 (4th Cir. 2018)Annotate this Case
Defendant pleaded guilty to multiple counts of sexual exploitation of a child and one count of receipt and distribution of child pornography. The Fourth Circuit dismissed defendant's challenge to the amount of restitution awarded to the contact victim because it fell within the scope of his appeal waiver. The court vacated the restitution order because the district court's reasons for denying restitution to the non-contact victims contradicted the Supreme Court's instruction in Paroline v. United States. Therefore, the court remanded for further proceedings to determine an appropriate amount of restitution for each non-contact victim.