What, if any, causal relationship or nexus between the defendant's conduct and the victim's harm or damages must the government or the victim establish in order to recover restitution under 18 U.S.C. § 2259?

question presented did not extend to how restitution should be determined if the proximate cause standard were adopted, the parties did not brief the issue. The Court nevertheless offered numerous “guideposts” (since dubbed “Paroline factors”) that district courts “might consider in determining a proper amount of restitution,” but twice expressly declined to offer more specific guidance, finding more precise instruction to be “neither necessary nor appropriate... at this point in the law’s development.” Id. at 459-60; see also id. at 462 (declining to provide “further detailed guidance at this stage in the law’s elaboration”). Since Paroline, however, district courts have likened restitution analysis to “piloting a small craft to safe harbor in a Nor’easter.” United States v. DiLeo, 58 F. Supp. 3d 239, 244 (E.D.N.Y. 2014). Throughout the country, restitution awards and methodologies vary widely; a significant circuit split has developed; and unwarranted disparities abound. This case presents two questions: 1. Whether — in the context of a criminal restitution request on behalf of a victim of child pornography — § 2259/Paroline requires disaggregation of losses sustained as result of the victim’s initial abuse, as distinct from those losses caused by the continuing traffic in the victim’s image(s). 2. Whether this Court should provide much needed guidance — both substantive and procedural — as to how district courts should apply the proximate cause standard adopted in Paroline v. United States, 572 U.S. 434 (2014). -i