Recently, the United States Supreme Court issued another ruling that impacts federal criminal cases. The issue in this recent case was whether the Defendant should get an automatic longer sentence that is imposed when “death results” from drugs that the Defendant sold. I previously posted about this case here, and the the recent decision (which was published when I was away on a well-needed vacation) is here.
In this recent case, the Supreme Court looked for the meaning of the term “result from” in a case where the district court imposed a 20-year mandatory minimum sentence upon a Defendant for the sale of one gram of heroin since a buyer’s death had “result[ed] from” the use of the heroin as one of several drugs he consumed that contributed to the death. The Defendant (a man named Burrage) had sold drugs to Banka, who died after using both Burrage’s heroin and several other drugs. Medical experts at trial could not say whether Banka might have died from using the other drugs even if he had not taken the heroin, but the experts all though that the heroin was a contributing cause of death.
The trial judge refused to go along with the Defendant’s argument the term “result from” is the same as a “but-for” standard. The Defendant basically said that the mandatory 20-year sentence only is applied when “but for” the Defendant’s drugs, the drug user would not have died. Both the trial court and the court of appeals rejected that argument, ruling that the phrase means that Burrage’s heroin only needed to be a “contributing cause” of the death.
In a unanimous opinion, the Supreme Court reversed, ruling that the term “result from” should be construed in its “ordinary meaning” to require a “but-for” standard of causation — that the harm would not have resulted “but for” the defendant’s conduct. Even if the drug sold by Burrage was a “contributing factor” to the drug user’s death, that was not enough for imposing the mandatory 20-year sentence.
Like all cases we keep tab as on, this opinion may have impacts beyond drug cases. The issue of what consequences resulted from a Defendant’s conduct arises in murder and assault cases. Additionally, it sometimes comes up in our white-collar cases. For example, this concept arises when determining the amount of loss or harm for sentencing purposes. In the end, it seems that in federal criminal law the term “result from” now will have a more narrow meaning than previously thought.