Opprescedent Decisions Continue for Victims of Child Pornography

Last month, in United States v. Robert M. Fast, the Eighth Circuit, in a 2-1 split decision, rejected full restitution for child pornography victims, holding that: Congress determined that these [child pornography] restitution offenses typically proximately cause the losses enumerated in subsections 2259(b)(3)(A) through (E). Congress did not mean that a specific defendant automatically proximately causes those losses in every case. The government still has to prove that the defendant proximately caused those losses. [I]njury to the child depicted in the child pornography…is a readily foreseeable result of distribution and possession of child ...