DePierre v. United States
United States Supreme Court
564 U.S. 70 (2011)
DePierre (defendant) was convicted of selling 55.1 grams of cocaine base under a statute imposing a mandatory 10-year minimum for 50 or more grams of "cocaine base," compared to only a 5-year minimum for 100 times that amount of plain "cocaine"; DePierre argued the statute's crack-focused legislative history, its disparity with the cocaine provision, potential absurd results, and the Sentencing Guidelines' crack-specific definition all showed "cocaine base" meant only crack, and that any remaining ambiguity should be resolved in his favor under the rule of lenity.
Whether success in prosecuting a controlled-substance violation may depend on the precision with which the applicable statute defines the substance's chemical composition.