A conviction for drug distribution under the federal Controlled Substances Act can carry a mandatory minimum sentence of 10 years in prison. “If death or serious bodily injury results from the use of such substance,” however, the mandatory minimum sentence doubles to 20 years.
But when is it fair to say that death or serious bodily injury “results” from a particular controlled substance? Would it be enough for someone to buy marijuana and then get into a car accident while smoking it, or slipped and fell on the way home?
That question was before the U.S. Supreme Court recently, in a case where the defendant was charged with heroin distribution resulting in an Iowa man’s death. On appeal, the question wasn’t whether the defendant sold the heroin; but whether it was the heroin that caused that man’s death.
The deceased, as it turns out, may have had as many as five other drugs in his system when he died — including oxycodone, a muscle relaxer, and two dangerous benzodiazepine sedatives.
It was a deadly cocktail, and two medical experts at trial admitted they couldn’t say for sure whether the heroin was the cause of death. The Iowa man might have died anyway. Nevertheless, the jury convicted the defendant, presumably because it seemed clear the heroin had contributed to the Iowa man’s death.
Yesterday, the U.S. Supreme Court unanimously ruled that isn’t enough to support a conviction. “The language Congress enacted requires death to ‘result from’ use of the unlawfully distributed drug,” Justice Antonin Scalia wrote for the majority, “not from a combination of factors to which drug use merely contributed.”
Five states have their own laws increasing sentences when a drug sale “contributes to” someone’s death or serious injury, although Florida hasn’t adopted that language. And neither, the court pointed out, has Congress.
Furthermore, whenever there is a question of how to interpret criminal statutes, courts should give the defendant the benefit of the doubt. This is called the rule of lenity, and “we cannot give the text a meaning that is different from its ordinary, accepted meaning, and that disfavors the defendant,” wrote Scalia.
This positive outcome for the defendant took years to achieve. Moreover, the defendant’s underlying conviction for heroin distribution still stands. If you’re ever accused of a federal drug crime, you need to contact an experienced federal defense attorney right away.
