United States v. Lewis, No. 17-3046 (8th Cir. 2018)
Annotate this CaseThe Eighth Circuit affirmed defendant's conviction of one count of conspiracy to distribute a mixture or substance containing heroin and furanylfentanyl resulting in death and serious bodily injury and one count of the substantive crime. The court held that the evidence was sufficient to support the conspiracy conviction; the sentencing enhancement found in USSC 841(b)(1)(C) was sustainable on the record where expert testimony provided by medical professionals established beyond a reasonable doubt that two individuals would not have overdosed and would not have died but-for the use of the drugs; and nothing in Burrage v. United States, 571 U.S. 204, 210 (2014), or the plain language of the statute limits responsibility to only the last person to distribute the drug before the harm occurs.
Court Description: Erickson, Author, with Loken and Gruender, Circuit Judges] Criminal case - Criminal law. Evidence was sufficient to support defendant's convictions for conspiracy to distribute heroin and furanylfentanyl and distribution of the drugs resulting in death and serious injury; sentencing enhancement found in 21 U.S.C. Sec. 841(b)(1)(C) was sustainable on this record as the expert testimony provided by the medical professionals established beyond a reasonable doubt that two victims would not have overdosed "but-for" the use of furanylfentanyl and that the third victim would not have died "but-for" the use of furanylfentanyl; nothing in Burrage or the plain language of the statute limits criminal responsibility to only the last person to distribute the drug before the harm occurs. [ July 12, 2018
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