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Amy And Vicky's Cause: Perils Of The Federal Restitution Framework For Child Pornography Victims, Robert W. Jacques
Amy And Vicky's Cause: Perils Of The Federal Restitution Framework For Child Pornography Victims, Robert W. Jacques
Georgia Law Review
Child pornography is unique among violent crimes in at
least one aspect: victims are harmed not only from their
initial abuse but also from knowing that people on the
Internet continue to view the images. In recent years, a
split has arisen among federal courts on whether victims
of child pornography are entitled to restitution from non-
production offenders, i.e., offenders that were not involved
in the initial abuse of victims. The controversy has
surrounded 18 U.S.C. § 2259-the mandatory restitution
statute for sex offenses. While some courts find victim
harm not sufficiently traceable to the crimes at issue to …