United States Court of Appeals for the Sixth Circuit · 2001-05-22
21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)
Case and law context
Role: applied; posture: criminal; guilty plea to a § 846 conspiracy to possess with intent to distribute and to distribute "a measurable quantity" of marijuana; defendant appeals the 120-month mandatory minimum imposed under § 841(b)(1)(B) on the district judge's preponderance finding of drug quantity (Apprendi); sentence vacated and remanded for resentencing; result: claimant-lost; claim: (b)(1)(B),(b)(1)(D)
Uncertainty
other: result is recorded for the § 841(b)(1)(B) quantity tier, the only § 841 question on appeal; the conspiracy conviction on the guilty plea stands
Misfit
None recorded
B · Case × element grid
Top-level elements follow claim order in panels of up to six elements. Case rows repeat across panels. Every recorded block retains its holding and basis; multiple blocks are not merged into a case-level verdict. ✓ satisfied · ✗ not satisfied · ○ not reached · · not addressed. Muted blocks are not counted. Sub-element evidence remains on case and element pages.
Elements 1–6 of 18
Elements 7–12 of 18
Elements 13–18 of 18
| Case | Drug conspiracy route under 21 U.S.C. § 846 (cross-statute) | Fifth Amendment Due Process / Equal Protection challenge to carrier-medium weight sentencing (Chapman) | Affirmative defense of entrapment (government inducement + lack of predisposition) | Rule of lenity in construing ambiguous penalty provisions of § 841(b) | Fifth Amendment void-for-vagueness challenge to "mixture or substance" or analogue provisions | Continuing-offense venue for § 841(a)(1) possession with intent to distribute / distribution (18 U.S.C. § 3237(a)) |
|---|---|---|---|---|---|---|
| United States v. Strayhorn — 250 F.3d 462 (2001) · United States Court of Appeals for the Sixth Circuit · 2001 (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed | · not addressed |
Instances and excluded annotation blocks
| Case | Element | Holding and scope | Pattern | Exact source quotations |
|---|---|---|---|---|
| United States v. Strayhorn — 250 F.3d 462 (2001) · United States Court of Appeals for the Sixth Circuit · 2001 — not reached (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Mens rea: "knowingly or intentionally" (including knowledge that the substance is a controlled substance) | not_reached Excluded from merits counts applied / merits claim: (b)(1)(B),(b)(1)(D) | Unspecified route | No source quotation recorded for this block. |
| United States v. Strayhorn — 250 F.3d 462 (2001) · United States Court of Appeals for the Sixth Circuit · 2001 — satisfied · conceded (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Recidivist enhancement for prior conviction for a serious drug felony or serious violent felony (§ 841(b)(1), 21 U.S.C. § 851) | satisfied Counted merits instance applied / merits basis: conceded; claim: (b)(1)(B),(b)(1)(D) Uncontested. The prior felony drug conviction set the default statutory maximum at 10 years under § 841(b)(1)(D), the baseline against which the Apprendi error was measured. | single-prior-felony-drug-conviction | Strayhorn’s criminal history category was determined to be level III, which included a prior felony drug offense.Source: docroot/ir/caselaw/f3d_250.jsonl#/f3d/250/0462-01; Unicode character offsets [6389:6502] (end exclusive); SHA-256 4e36f0efbac9dfc678e7da85ac0d7813765b7710d429828e0c4a9b5487c5aa94. |
| United States v. Strayhorn — 250 F.3d 462 (2001) · United States Court of Appeals for the Sixth Circuit · 2001 — not · law (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Partial penalty-tier drug type and quantity table (selected § 841(b)(1)(A)-(D) hook) | not Counted merits instance applied / merits basis: law; claim: (b)(1)(B),(b)(1)(D) Sentence vacated under Apprendi: a judicial finding of 100+ kilograms of marijuana by a preponderance, moving the defendant from a 10-year maximum under § 841(b)(1)(D) to a 10-year mandatory minimum under § 841(b)(1)(B), is an element that must be charged and proved beyond a reasonable doubt even after a guilty plea. The quantity was never found to the required standard; on remand the district court may find it beyond a reasonable doubt or resentence under (b)(1)(D). | judge-found-quantity-raises-max-to-mandatory-minimum-after-guilty-plea | The court noted that Phillips had testified that he purchased or was “fronted” approximately 260 pounds of marijuana from Strayhorn, in addition to the 88 pounds which were actually seized.Source: docroot/ir/caselaw/f3d_250.jsonl#/f3d/250/0462-01; Unicode character offsets [8179:8368] (end exclusive); SHA-256 4e36f0efbac9dfc678e7da85ac0d7813765b7710d429828e0c4a9b5487c5aa94.While acknowledging his guilt for the amount of marijuana seized from his home and from co-defendant Phillips, he explicitly denied responsibility for any additional marijuana for which the government sought to hold him responsible.Source: docroot/ir/caselaw/f3d_250.jsonl#/f3d/250/0462-01; Unicode character offsets [4041:4273] (end exclusive); SHA-256 4e36f0efbac9dfc678e7da85ac0d7813765b7710d429828e0c4a9b5487c5aa94.Strayhorn never pleaded guilty to the elements of the offense under § 841(b)(1)(B) nor were they charged or proved beyond a reasonable doubt.Source: docroot/ir/caselaw/f3d_250.jsonl#/f3d/250/0462-01; Unicode character offsets [22262:22403] (end exclusive); SHA-256 4e36f0efbac9dfc678e7da85ac0d7813765b7710d429828e0c4a9b5487c5aa94.Already, we have held, pursuant to Apprendi, that the government must name in the indictment the quantity of drugs for which it seeks to hold the defendant responsible under 21 U.S.C. § 841(a), and that the determination of drug quantity under § 841(b) must, when it subjects the defendant to an enhanced sentence, be considered an element of the offense rather than a sentencing factor.Source: docroot/ir/caselaw/f3d_250.jsonl#/f3d/250/0462-01; Unicode character offsets [15360:15747] (end exclusive); SHA-256 4e36f0efbac9dfc678e7da85ac0d7813765b7710d429828e0c4a9b5487c5aa94.Because the district court’s factual finding of drug quantity by a preponderance of the evidence transformed the crime to which the defendant pleaded guilty (conspiracy to possess less than fifty kilograms of marijuana punishable by a maximum ten-year sentence) into a greater crime for the purposes of sentencing (conspiracy to possess over 100 kilograms of marijuana punishable by a mandatory minimum ten-year sentence), the district court’s finding violated Strayhorn’s Fifth and Sixth Amendment rights.Source: docroot/ir/caselaw/f3d_250.jsonl#/f3d/250/0462-01; Unicode character offsets [25068:25574] (end exclusive); SHA-256 4e36f0efbac9dfc678e7da85ac0d7813765b7710d429828e0c4a9b5487c5aa94. |
| United States v. Strayhorn — 250 F.3d 462 (2001) · United States Court of Appeals for the Sixth Circuit · 2001 — satisfied · conceded (21usc841: author: Flash2 · QA: FIX (Fable, neov2/cases/TRIAGE-Flash.md)) | Controlled substance (21 U.S.C. §§ 802(6), 812 Schedules I-V) or counterfeit substance (§ 841(a)(2)) | satisfied Counted merits instance applied / merits basis: conceded; claim: (b)(1)(B),(b)(1)(D) Marijuana; the defendant accepted responsibility for the 88 pounds seized. | marijuana-seized-and-admitted-by-plea | From the information gleaned from these recordings, federal agents executed a search at Strayhorn’s residence on January 17, 1998, where they recovered 48 pounds of marijuana, $3,000 in cash, and a handgun.Source: docroot/ir/caselaw/f3d_250.jsonl#/f3d/250/0462-01; Unicode character offsets [2164:2370] (end exclusive); SHA-256 4e36f0efbac9dfc678e7da85ac0d7813765b7710d429828e0c4a9b5487c5aa94. |