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

QUESTION PRESENTED In Paroline v. United States, 572 U.S. 434 (2014), the Court addressed how to calculate restitution for criminal defendants convicted of possessing child pornography. In doing so, the Court parenthetically observed that “[c]omplications 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. at 449. In this case, the Eleventh Circuit held that Paroline does not require the losses sustained as a result of the initial physical abuse to be “disaggregated” from the losses sustained as a result of trafficking in the victim’s images. In so holding, the Eleventh Circuit joined the Eighth Circuit and rejected contrary holdings by the Ninth and Tenth Circuits. The D.C. Circuit has since joined the Eighth and Eleventh Circuits. The question presented is: When calculating restitution for a possessor of child pornography, must the victim’s losses caused by the initial physical abuse be disaggregated from the losses caused by the subsequent traffic in the victim’s images? i