In a case heard recently, the U.S. Supreme Court was asked to decide whether a victim seeking restitution under the 1994 Violence Against Women Act must prove causal connection to her harm and what an appropriate recovery would be. Congress authorized a recovery for the victims of child pornography against perpetrators who are convicted of producing, distributing or possessing their images.

Amy Unknown, the victim in Paroline v. United States, was sexually assaulted by her uncle when she was 8 years old. He also videotaped the outrage. The uncle pleaded guilty in both state and federal courts and was sentenced to 12 years in prison in each jurisdiction, but the terms were not consecutive.

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