United States v. Mahaffey, No. 19-6061 (6th Cir. 2020)
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Mahaffey and another were arrested at the Cincinnati Airport for suspected drug trafficking. Each possessed luggage containing about 40 pounds of vacuum-sealed marijuana. Hidden within one of Mahaffey’s marijuana parcels was four pounds of methamphetamine. They were charged under 21 U.S.C. 841(a)(1), 846 with conspiracy to possess with the intent to distribute methamphetamine, possession with the intent to distribute methamphetamine, and possession with the intent to distribute marijuana. The government did not establish that Mahaffey knew about the methamphetamine. A jury convicted him of all counts and attributed to him 500 grams or more of a mixture containing methamphetamine. The district court then imposed a mandatory-minimum sentence of 10 years.
The Sixth Circuit affirmed, upholding its precedent that a drug-trafficking conviction under section 841 does not require proof that the defendant knew the type or quantity of controlled substance involved in the offense. The Supreme Court’s 2019 “Rehaif” holding did not abrogate that precedent. Rehaif involved possession of firearms; its scienter focus is not a new legal development or a fit for section 841. It is not unusual to punish individuals for the unintended consequence of their unlawful acts. Mahaffey knew that his planned conduct was wrongful. That he did not appreciate the exact consequences of his predetermined criminal conduct, that it “involved” large amounts of methamphetamine under section 841(b)(1), makes no difference for purposes of his decision to unlawfully possess a controlled substance with the intent to distribute.
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