Burrage v. United States
United States Supreme Court
571 U.S. 204, 134 S. Ct. 881 (2014)
- Written by Jamie Milne, JD
Facts
Marcus Burrage (defendant) sold heroin to Joshua Banka. Before Banka purchased the heroin, he smoked marijuana and injected oxycodone. After buying the heroin, Banka injected it multiple times that night. Banka died of a drug overdose. Burrage was charged with violating the enhanced-penalty provision of the federal Controlled Substances Act (act), which applies if a death or serious bodily injury results from the use of an unlawfully distributed substance. At trial, two medical experts testified that Banka had heroin, alprazolam, clonazepam, and oxycodone in his system at death. Both experts testified that while the heroin was a contributing factor in Banka’s death, they could not say whether Banka would have lived had he not taken the heroin. The trial judge instructed the jury that Burrage was liable if the heroin was a contributing cause of Banka’s death. The jury convicted Burrage, and he was sentenced to the mandatory minimum of 20 years. The court of appeals affirmed, and Burrage appealed to the United States Supreme Court.
Rule of Law
Issue
Holding and Reasoning (Scalia, J.)
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