United States v. Hoskins, No. 16-3532 (8th Cir. 2017)Annotate this Case
The Eighth Circuit affirmed the district court's order of restitution in a case where defendant was convicted of distributing a visual depiction of a minor engaging in sexually explicit conduct. The court held that the district court's estimate of future psychological damages, based on the testimony of the victim's mother and the documented expenses already incurred, where not clearly erroneous. The court also held that the evidence before the district court provided a basis to conclude that some of the victim's losses were uniquely caused by defendant distributing the video of her assault. Therefore, the district court did not abuse its discretion in deciding to award restitution and it did not clearly err in assessing the amount of restitution awarded.