Rule of Lenity

In January, the U.S. Supreme Court applied the rule of lenity in a criminal case.  The rule of lenity is a rule of statutory construction that resolves ambiguities in statutory language in favor of the defendant.
The case involved a defendant who was convicted of selling heroin to a user, who then died.  The Court discussed applying the 20-year minimum sentencing enhancement that is applied to a defendant in this situation.  The Eight Circuit Court of Appeals held that it was enough under the statute to prove that the substance was a “contributing cause” of the victim’s death.
In analyzing this statute, the Supreme Court discusses the language of the statute, which requires death to “result from” the use of the unlawfully distributed drug.  The Supreme Court reasoned that in writing this statute, Congress could have used language that implied that the drug “contributed to” the death.  Instead, Congress used language that implied but-for causality.  The Supreme Court refused to give the statute meaning other than its ordinary and accepted meaning, especially a meaning that disfavored the defendant.  Accordingly, the Supreme Court held that the government must prove beyond a reasonable doubt that, but for the use of that particular substance, the victim would be alive.
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