purple logo

When is it fair to say a death 'resulted' from illegal drug use?

The mandatory minimum sentences for drug distribution under the federal Controlled Substances Act are harsh. When the defendant’s drugs resulted in someone suffering a serious injury or death, however, the mandatory minimum sentence is 20 years.

When someone is facing two decades in federal prison, how clear should it have to be that the illegal drugs he or she sold actually caused an injury or death? That question was just answered by the U.S. Supreme Court.

The case involved a man known as Lil C who was charged with distributing heroin that prosecutors said resulted in the death of an Iowa man in 2010. The problem with that theory was that the Iowa man’s unfortunate death occurred after he binged on multiple drugs. He took the heroin, but he had also crushed up pills of the painkiller oxycodone and then cooked and injected the mixture. Other drugs, including benzodiazepine sleeping pills, were found in his home.

Two medical experts testified at trial, but neither could say for certain whether the heroin caused the Iowa man’s death. The most they could honestly claim was that it was "very less likely" he would have died if not for the heroin in his deadly drug cocktail.

That was enough for a jury, which convicted Lil C of distributing an illegal substance and assigned the 20-year sentence the Controlled Substances Act requires “if death or serious bodily injury results from the use of such substance.”

It was not enough for the Supreme Court, which unanimously overturned that part of Lil C’s conviction this week.

The government had argued it would be better public policy to hold defendants like Lil C responsible when the drugs they sell contribute to injuries and deaths. For better or worse, answered Justice Antonin Scalia for the court, that doesn’t matter here. It’s not the courts’ role to write better laws but to interpret them as written.

Congress could have chosen to write the statute so that dealers could be held responsible if a drug they sold “contributes to” an injury or death -- but it didn’t he said.

"It chose instead to use language that imports but-for causality," he wrote, referring to the phrase “results from” in the statute. And, when there’s any doubt about what a criminal statute means, our system of justice requires that the defendant is given the benefit of that doubt.

Source: Courthouse News Service, “Justices Toss Conviction in Heroin-Linked Death,” Barbara Leonard, Jan. 27, 2014

No Comments

Leave a comment
Comment Information
purple logo