Case Explained: United States of America Plaintiff— v. Matthew Matherne Defendant—

Court: United States Court of Appeals for the Fifth Circuit Filed: 2026-06-18 The Fifth Circuit affirmed the district court’s restitution award in a child pornography case but vacated and remanded for a clerical correction to increase the total amount. The court held that the government met its burden under 18 U.S.C. § 2259 by presenting sufficiently reliable evidence, including a letter from the victim’s counselor, a curriculum vitae, and a cost-estimate chart, to support projected future treatment costs of $139,628. The court applied an abuse of discretion standard for the quantum of the award and clear error for factual findings, determining that the defendant failed to show the evidence lacked indicia of reliability or that the district court abused its discretion in finding causation between the offense and the victim’s losses. Specifically, the court ruled that under § 2259(c)(2), the government was not required to prove the necessity of medical or psychological services, and pre-existing trauma did not negate the impact of the defendant’s crime. However, the court identified a mathematical error in the district court’s judgment where the “Family Consultation” subtotal was calculated as $300 instead of the correct $3,000. Consequently, the court vacated the original award of $155,225.48 and remanded for the entry of an amended final judgment increasing the total restitution to $157,955.48 pursuant to Federal Rule of Criminal Procedure 36. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.