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McFadden v. United States

135 S. Ct. 2298, 192 L. Ed. 2d 260 (2015)

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McFadden v. United States

United States Supreme Court

135 S. Ct. 2298, 192 L. Ed. 2d 260 (2015)

Facts

Federal agents began investigating a store for selling bath salts, a type of recreational drug. The store owner agreed to assist the investigators by making a purchase of controlled substances from her supplier, Stephen McFadden (defendant). McFadden advertised his products under names related to controlled substances, including “speed,” and compared them to recreational drugs. McFadden marked his products as “not for human consumption” and noted on the labels that the products did not contain certain compounds or analogues of those compounds. The packages sent from McFadden to the store owner contained small plastic bags of powder. These powders were tested and confirmed to produce the same effects as several controlled substances if consumed. McFadden was indicted and tried in federal district court on charges that included the distribution of controlled-substance analogues. McFadden argued at trial that he did not know that the substances he sold as bath salts were regulated under the Controlled Substances Analogue Enforcement Act of 1986 (the act). The government (plaintiff) and McFadden disagreed about proper mental-state requirement under the act. The district court ultimately issued a jury instruction stating that under the act, McFadden could be found guilty if the jury determined that McFadden knowingly distributed a substance for human consumption, even if McFadden was not aware that the substance was an analogue of a controlled substance. The jury convicted McFadden, and McFadden appealed. The court of appeals affirmed the district court, and McFadden appealed to the United States Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Thomas, J.)

Concurrence (Roberts, C.J.)

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