Burrage v. United States

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Sentencing
  • Date Filed: January 27, 2014
  • Case #: 12-7515
  • Judge(s)/Court Below: SCALIA, J., delivered the opinion of the Court, in which the ROBERTS, C. J., and KENNEDY, THOMAS, BREYER, and KAGAN, JJ., joined, and in which ALITO, J., joined as to all but Part III–B. GINSBURG, J., filed an opinion concurring in the judgment, in which SOTOMAYOR, J., joined.
  • Full Text Opinion

A drug distributed by a defendant must be the "but-for" cause of death or serious injury before that defendant can be liable under the Controlled Substances Act’s penalty enhancement provision.

Petitioner sold heroin to a drug user who died after taking the heroin in combination with several other drugs. Petitioner was charged under the Controlled Substances Act (the Act), which carries a 20-year mandatory-minimum sentence when a defendant distributes a Schedule I or II drug and “death or serious injury results from the use of such substance.” At trial, two expert witnesses testified that the heroin was a contributing cause of the drug user’s death, but neither witness could say that the drug user would have lived had he not taken the heroin. Petitioner moved for a judgment of acquittal, arguing that the Government did not prove that the heroin was the “but -for” cause of the drug user’s death, and therefore the death did not “result from” taking the heroin. The district court denied the motion and instructed the jury that the Government was only required to prove that the heroin was a “contributing cause” of death. The jury convicted Petitioner and Petitioner appealed.

The Eight Circuit affirmed, holding that the district court’s contributing-cause instruction was consistent with an earlier decision.

The Supreme Court reversed the decision of the Eight Circuit and remanded the case. Looking to the ordinary meaning of “results from,” the Court concluded that the penalty enhancements provision required “but-for” causation. Accordingly, the Court held that the drug distributed by a defendant must be the “but-for” cause of death or serious injury before the Act’s penalty enhancement provision applies.

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