Burrage v. United States
United States Supreme Court
134 S. Ct. 881 (2014)
Marcus Burrage (defendant) sold heroin to Joshua Banka, who had already used marijuana and oxycodone that day and then injected the heroin repeatedly overnight before dying of a multi-drug overdose; two medical experts agreed the heroin contributed to Banka's death but neither could say Banka would have survived without it. Burrage was convicted under a Controlled Substances Act provision imposing a mandatory 20-year minimum where death "results from" the distributed substance's use, based on a jury instruction that heroin only needed to be a contributing factor, and he appealed.
Whether, under the Controlled Substances Act, the enhanced punishment for distributing a drug that results in death or serious bodily injury applies only if that particular drug's use was the but-for cause of the death or injury.