United States v. Palmer, No. 18-1365 (8th Cir. 2019)
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The Controlled Substance Analogue Enforcement Act is not unconstitutionally vague where the statute's "knowingly or intentionally" scienter requirement alleviates vagueness concerns by narrowing the scope of its prohibition, and limiting prosecutorial discretion.
The Eighth Circuit affirmed Defendant Palmer and Leinicke's convictions for several conspiracy crimes related to their participation in a conspiracy to distribute synthetic narcotics. The court declined to apply the categorical approach and held that defendants failed to show that the Act was unconstitutionally vague as applied to them. Finally, the court held that the indictment alleged sufficient facts to show Palmer's knowledge that his conduct violated the Act.
Court Description: Wollman, Author, with Gruender and Shepherd, Circuit Judges] Criminal case - Criminal law. The Controlled Substance Analogue Enforcement Act is not unconstitutionally vague, and the district court did not err in denying defendants' motion to dismiss the indictment on this ground; the statute's "knowingly or intentionally" scienter requirement alleviates vagueness concerns by narrowing the scope of its prohibition and limiting prosecutorial discretion; as-applied challenge to the Act's constitutionality rejected; indictment alleged sufficient facts to show defendant Palmer's knowledge that his conduct violated the Act.
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