United States v. Seals, No. 18-1042 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit held that there was sufficient evidence to convict defendant of distribution of heroin and fentanyl resulting in serious bodily injury and possession of those drugs with intent to distribute. In this case, viewing the evidence in the light most favorable to the jury verdict, there was overwhelming evidence presented to the jury to establish but-for causation. Even if the jury had determined that the acetyl-fentanyl was an independently sufficient cause of the overdose, Burrage v. United States explicitly carved out an exception for cases where there are multiple independently sufficient causes. The court found that the jury drew reasonable inferences from the evidence that a third party's overdose was not caused by any opiate in his system prior to the ingestion of the heroin/fentanyl mixture he purchased from defendant.
Court Description: Erickson, Author, with Loken, Circuit Judge, and Magnuson, District Judge] Criminal case - Criminal law. Evidence was sufficient to support defendant's convictions for distribution of heroin and fentanyl resulting in serious bodily injury and possession of those drugs with intent to distribute; the evidence on the serious bodily injury count was sufficient to meet the Burrage standard of but-for causation.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.