Pulsifer v. United States
United States Supreme Court
601 U.S. 124 (2024)
- Written by Sean Carroll, JD
Facts
Mark Pulsifer (defendant) pled guilty to drug charges carrying a mandatory minimum sentence of 15 years. Pulsifer had two three-point criminal offenses on his record. Pulsifer argued that he was entitled to relief from the mandatory minimum sentence under the safety-valve provision in the First Step Act (the act). The act provided that a defendant could get relief from a mandatory minimum sentence if five criteria were met, including one related to criminal history. The criminal-history provision required that the defendant not have more than four criminal-history points, a three-point offense, and a two-point violent offense. Pulsifer had two three-point offenses for a total of six criminal-history points. Pulsifer argued that he was entitled to relief under the act because he did not have a two-point violent offense. The government (plaintiff) argued that a defendant must meet each of the three requirements within the criminal-history provision to qualify for that provision. The United States Court of Appeals for the Eighth Circuit sided with the government. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Kagan, J.)
Dissent (Gorsuch, J.)
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