In Paroline v. United States, the Supreme Court was asked to determine the amount of restitution a victim of child pornography could receive from an individual who possessed images of their abuse but did not directly cause it. The case involved Doyle Randall Paroline, who had been found guilty for possessing two images among thousands involving "Amy," whose uncle abused her as a young girl and distributed photos online. Amy sought full restitution under 18 U.S.C §2259 for losses incurred due to the ongoing trafficking of her childhood sexual abuse images - around $3.4 million in total damages. The court ruled in April 2014 that while victims should be compensated by those convicted of creating, distributing or possessing their child pornography, they cannot collect full damages from one defendant unless that person's actions were solely responsible for all harm suffered by the victim. Instead, each offender is liable only for a reasonable part of the victim’s total losses attributable to his role in this crime.

In the dissenting opinion for Paroline v. United States, Chief Justice Roberts, joined by Justices Scalia and Thomas, disagreed with the majority's interpretation of 18 U.S.C. §2259 - a statute requiring defendants to pay restitution to victims of child pornography. The dissent argued that this law mandates full restitution from each defendant who contributed to the victim’s harm but not necessarily in proportion to their individual roles in causing it. They contended that under this reading, Amy (the victim) would receive complete compensation for her losses without having to pursue countless lawsuits against every individual involved in her exploitation – an outcome they believed was more consistent with Congress' intent when drafting the legislation. Justice Sotomayor also dissented separately arguing that any person convicted of possessing child pornography should be held liable for all damages suffered by the victim as a result of its creation and dissemination regardless if they directly caused them or not.