Conage v. United States
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The Supreme Court held that a completed purchase of illegal drugs necessarily entails the defendant purchaser's possession of those drugs, as federal law defines possession, and a purchase is not necessarily complete as soon as the would-be purchaser pays for the drugs.
Defendant was convicted of a gun possession crime and sentenced to a mandatory prison term under the Armed Career Criminal Act (ACCA) after the trial court concluded that Defendant had three previous convictions for a "serious drug offense" as defined by the ACCA. At issue was whether one of Defendant's previous drug trafficking offenses met the ACCA's definition of a "serious drug offense." On appeal, Defendant argued that a purchase is complete upon payment by the defendant, and therefore, a completed purchase does not require proof that Defendant possessed the purchased drugs. The Eleventh Circuit Court of Appeal certified the question to the Supreme Court. The Court answered that, for purposes of Fla. Stat. 893.135(1), a completed purchase requires proof that Defendant both gave consideration for and obtained control of a trafficking quantity of illegal drugs.
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