The issue of restitution in child-pornography cases has been one we've talked about quite a bit here, at CDAM conferences, and elsewhere. On June 27, 2013, the Supreme Ct. granted cert in Paroline v. United States, No. 12--8561.
Issue:
"What, if any, causal relationship or nexus between the defendant's conduct and the victim's harm or damages must the government or the victim establish in order to recover restitution under 18 U.S.C. Sec. 2259?"
Briefs were submitted August 19, 2013, but additional briefing is still pending.