Paroline, Restitution, and Transferred Scienter: Child Pornography Possessors and Restitution Based on a Commerce-Clause Derived, Aggregate Proximate Cause Theory

This Article poses a more logical and legal construct, derived from Commerce Clause analysis, that although each individual possessor of child pornography appears to contribute almost imperceptibly to the victim’s harm, the aggregate effect of possession is sufficient to satisfy the causal nexus required for restitution.