United States v. Jeffries
958 F.3d 517 (6th Cir. 2020)
Nature Of The Case
This section contains the nature of the case and procedural background.
Facts
J.H.'s body was discovered with a small bag of brown powder, later determined to be .58 grams of fentanyl. The officers found text messages in J.H.'s cellphone that indicated that she had attempted to buy or had bought drugs from D earlier that day. The officers, pretending to be J.H., texted D and requested more drugs. D arrived at J.H.'s home, and the officers arrested him. A search revealed separately packaged bags holding 1.69 grams of fentanyl, as well as a cellphone containing the text messages sent from J.H.'s cellphone. In D's pocket, the officers found $446 and another bag of fentanyl, containing 36.14 grams of fentanyl. D was charged with one count of possessing fentanyl with intent to distribute and one count of distributing fentanyl, the use of which resulted in death. Two medical experts testified that the amount in J.H.'s system was 'significantly above the lethal level' and that no other 'anatomical issues' could have caused J.H.'s death. D asked the district court to instruct the jury that, to impose § 841(b)(1)(C)'s sentencing enhancement, the government was required to 'prove beyond a reasonable doubt that the death of J.H. was the natural and foreseeable result of the defendant's actions.' The court declined. It instructed the jury on but-for causation. The jury returned a guilty verdict and found that § 841(b)(1)(C)'s sentencing enhancement applied to the distribution count. D filed a motion for a new trial. It then viewed § 841(b)(1)(C)'s language as ambiguous and inserted a proximate-cause requirement into the penalty enhancement and granted a new trial. P appealed.
Issues
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Holding & Decision
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Legal Analysis
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