When calculating restitution for a mere possessor of child pornography, must the victim's losses caused by the initial abuse be disaggregated from the losses caused by the traffic in her images?

QUESTION PRESENTED In Paroline v. United States, 572 U.S. 434 (2014), the Court held that, in calculating restitution for defendants convicted of possessing child pornography, district courts “should order restitution in an amount that comports with the defendant’s relative role in the causal process that underlies the victim’s general losses.” Id. at 458. The Court defined “general losses” as those “that stem from the ongoing traffic in her images.” Jd. at 449. And the Court observed: “Complications may arise in disaggregating losses sustained as a result of the initial physical abuse, but those questions may be set aside for present purposes.” Id. In this case, the district court awarded $142,600 in criminal restitution to nine victims. As a mere possessor of their images, Petitioner argued that the district court was required to disaggregate the losses caused by the initial abuse from those caused by the traffic in her images. The Eleventh Circuit held that Paroline did not require such disaggregation. In so holding, that court joined the Eighth Circuit and rejected the contrary holdings of the Ninth and Tenth Circuits. The question presented is: When calculating restitution for a mere possessor of child pornography, must the victim’s losses caused by the initial abuse be disaggregated from the losses caused by the traffic in her images? i