United States v. Crawford, No. 11-5544 (6th Cir. 2013)
Annotate this CaseIn unrelated child pornography convictions, Gamble and Crawford were ordered by their respective district courts to pay over $1,000,000 in restitution to “Vicky,” the pseudonym of one of the individuals depicted in the images they possessed or received. Restitution was ordered jointly and severally under 18 U.S.C. 2259, which makes restitution mandatory for “the full amount of the victim’s losses” in child exploitation cases. The Sixth Circuit remanded because the district courts did not require a showing of proximate cause between the losses and the defendants’ offenses. Sixth Circuit case law requires such a showing. On remand the district court must reconsider the extent to which the defendants must pay restitution where they share responsibility for Vicky’s injuries with hundreds of other child pornography viewers.
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