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Home / Courts / 4th Circuit / Criminal Practice – Child Pornography – Sentencing – Restitution – Insufficient Findings (access required)

Criminal Practice – Child Pornography – Sentencing – Restitution – Insufficient Findings (access required)

U.S. v. Burgess The 4th Circuit affirms defendant’s conviction of receipt and possession of child pornography, but vacates a restitution order requiring defendant to pay $305,220 to “Vicki,” an identified victim; the district court did not make specific findings regarding the elements of restitution, as required under the Mandatory Restitution for Sexual Exploitation of Children Act, 18 U.S.C. 2259, and the case is remanded for calculation of the loss this specific defendant caused the victim portrayed in the pornographic material possessed by defendant.

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