NACDL News: Supreme Court Reverses Sentencing Enhancement in Drug Case

 A unanimous U.S. Supreme Court issued an important criminal law ruling on January 27 in the case of Burrage v. United States by applying the rule of lenity — a rule of statutory construction that resolves ambiguities in the language of a law in favor of the defendant. Reversing the Eighth Circuit Court of Appeals, the Court held that to apply the 20-year minimum sentencing enhancement in § 841(b)(1)(C) to someone convicted of selling certain substances to a user who then dies, “at least where use of the drug distributed by the defendant is not an independently sufficient cause of the victim’s death or serious bodily injury[,]” the government must prove beyond a reasonable doubt that “but for” the use of that particular substance, the user of the drug would be alive.