United States v. Marshall
United States Court of Appeals for the Seventh Circuit
908 F.2d 1312 (1990)
Stanley Marshall and three co-defendants were convicted of distributing LSD and sentenced under the Controlled Substances Act's mandatory minimums, which are calculated by the weight of any "mixture or substance containing a detectable amount" of the drug; because pure LSD doses are minuscule, LSD is typically sold dissolved onto paper or gelatin carriers, and the trial court included the weight of that carrier paper in calculating the defendants' mandatory minimum sentences, producing much harsher sentences than the pure drug's weight alone would have yielded.
Whether, first, the meaning of similar statutory language used in multiple provisions may be determined by comparing those provisions to each other, and second, whether a court may depart from a statute's clear text to reach a more just result absent relevant legislative history.