You'd have to imagine, at some point, that either Congress (ha!) or the Supreme Court will step in and clear up the confusion surrounding restitution for those depicted in child pornography, as well as the issue of joint and several liability of the present day possessors of the images. Though they've denied certiorari in Amy and Vicky cases before, the flood of circuit court confusion and circuit splintering continues.
Last September, the ABA Journal wrote an exhaustive feature on Amy and Vicky, the two victims who have had cases appear in nearly every federal Circuit Court of Appeals in the nation. In fact, they've had two opinions released regarding their restitution this week, including a writ of mandamus in the Ninth Circuit.