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Neal v. United States
United States Supreme Court
516 U.S. 284, 116 S.Ct. 763, 133 L.Ed.2d 763 (1996)
In 1988, Meirl Neal (defendant) pleaded guilty before the United States District Court for the Central District of Illinois to selling lysergic acid diethylamide (LSD) on blotter paper. In determining the length of Neal’s sentence, the district court considered the mandatory minimum sentence set by statute and the sentencing range set by the United States Sentencing Guidelines (the guidelines), both of which were based on the total weight of the LSD mixture or substance. At the time, both the statute and the guidelines considered the weight of LSD to include the full weight of the blotter paper used to absorb it. In this case, the district court determined the weight to be 109.51 grams, which corresponded to a 10-year minimum sentence under the statute and a 188- to 235-month sentence under the guidelines. The court sentenced Neal to 192 months’ imprisonment. Subsequently, the United States Sentencing Commission (the commission) revised the guidelines to establish a new method of calculating the weight of LSD. Rather than measuring the actual weight of the mixture or substance, the amended guidelines assigned each dose of LSD a presumptive weight of 0.4 milligrams. The presumptive weight in Neal’s case was 4.58 grams, which corresponded to a sentence of 70–87 months’ imprisonment. Neal filed a motion to modify his sentence, arguing that the presumptive-weight methodology should be used to calculate the mandatory minimum sentence. The district court determined that under the statute, the actual weight should be used and that the 10-year minimum sentence still applied. But because the guidelines no longer provided for a greater sentence, the district court reduced Neal’s sentence to 120 months. The Court of Appeals for the Seventh Circuit affirmed the sentence. Neal petitioned for certiorari.
Rule of Law
Holding and Reasoning (Kennedy, J.)
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