US Supreme Court overturns drug conviction sentence enhancement
On January 27, 2014, the U.S. Supreme Court issued a decision in Burrage v. U.S., a case dealing with a man who was convicted of distributing heroin and received a 20-year sentence enhancement because the man to whom he sold the drugs died after taking the drugs. The Court’s decision clarifies the situations when a sentence enhancement under federal sentencing guidelines is appropriate for drug crime convictions.
Heroin distribution conviction
The case came before the Court because a man was convicted of distributing heroin and the enhanced charge of distributing heroin that resulted in death in 2011. The man sold drugs to longtime drug user in April 2010, and the buyer died after “near-continuous” drug use for two days. The buyer’s wife identified the man as the one who sold the buyer drugs, and also reported that her husband used a number of drugs in addition to heroin in the time leading up to his death, such as marijuana and oxycodone.
At the man’s trial, a forensic toxicologist testified that the buyer’s heroin use was a factor that contributed to his death. However, the toxicologist could not testify with certainty that they buyer would not have died had he not used the heroin. In addition, the medical examiner who had performed the autopsy on the buyer testified that while it was “very less likely” that the buyer would not have died without taking heroin, she could not be certain that he would have lived without taking heroin.
The jury was instructed that it only needed to find the heroin was a contributing factor to the buyer’s death in order to convict the man of distributing heroin that resulted in death. The jury convicted the man of both charges, and he received concurrent 20-year prison sentences, the lowest sentence allowed under the Controlled Substances Act for such a conviction.
The man appealed his conviction and sentence for distributing heroin that resulted in death, arguing that the state needed to prove that the heroin was the cause of death – not just that it was a contributing factor. The U.S. Supreme Court agreed with the man, reasoning that it was common in both criminal and civil law to interpret the phrase “resulting from” to mean “actual cause.”
In this case, the state was unable to show that the heroin use was the actual cause of the buyer’s death, so the Court overturned the conviction and 20-year sentence for distributing heroin that resulted in death. The man is still serving 10 years in prison for his other conviction.
Drug charges are serious matters
As the facts in Burrage demonstrate, drug charges can have serious repercussions. Those who have been charged with crimes related to drugs should seek the assistance of a seasoned criminal defense attorney with a broad range of experience crafting defense strategies in drug crimes cases to help minimize the impact that such charges can have on their lives.