United States v. Jeffries

Police officers found fentanyl next to J.H.’s dead body and a phone with text messages showing that J.H had purchased fentanyl from Jurmaine Jeffries (defendant) earlier that day. The officers texted Jeffries, pretending to be J.H. and requesting additional fentanyl. They arrested Jeffries when he arrived at J.H.’s home. The officers found small bags of fentanyl in Jeffries’s car plus $446 and a larger bag of fentanyl on Jeffries’s person. Jeffries was charged under federal law with distribution and possession with intent to distribute. The government also charged a sentencing enhancement based on J.H.’s death, which medical experts testified was caused by fentanyl. Jeffries requested a jury instruction saying that the sentencing enhancement applied only if Jeffries’s conduct was the proximate cause of J.H.’s death, meaning that the death was a natural and foreseeable consequence. The district court declined the requested instruction and instead instructed that only but-for causation was necessary, meaning that the sentencing enhancement applied if J.H.’s death would not have occurred but for Jeffries’s conduct. The jury found Jeffries guilty and imposed the sentencing enhancement. Jeffries moved for a new trial, arguing that the district court’s jury instruction was erroneous. The district court agreed and ordered a new trial. The government appealed that order.