Chapman v. United States — 500 U.S. 453 (1991) · Supreme Court of the United States · 1991

Role: applied; posture: criminal; sentencing after conviction for LSD distribution, affirmed by CA7 en banc; certiorari by defendants on whether carrier weight counts toward the mandatory-minimum threshold; result: claimant-won; claim: (a),(b)(1)(B)(v)

Uncertainty

None recorded

Misfit

The opinion is purely about a (b) penalty threshold; guilt under (a) is not in issue. "quantity : satisfied [law]" stretches the element model: the fact (5.7 g gross / 50 mg net) was undisputed and the only question was which measurement the statute means. A measurement-rule construct (how the quantity is computed) would fit better than satisfied/not-satisfied. One fact line states both weights and so carries both polarities (gross supports the threshold, net cuts against it); it is tagged [supports].

Constitutional challenges to the statute (due process/equal protection, vagueness) and interpretive canons (lenity, constitutional avoidance) are recorded as x- defenses under `scope procedural`, which keeps them out of the instance count; but they are attacks on the law or arguments about its construction, not affirmative defenses of a party, and there is still no "validity of the law" or "canon rejected" slot. The only `fact` under the due-process block is the petitioners' contention, to which polarity does not really apply.

Dissent (Stevens, joined by Marshall) would exclude the carrier weight; v1 could hold it in a `scope dissent` block, but none is recorded because the v0->v1 migration adds no quotes.

The same holding governs the Sentencing Guidelines base offense level (USSG 2D1.1), a different legal instrument that tracks the statutory phrase; no way to note a parallel non-statutory rule.

IR text flattens a table in a footnote (disparate sentences per carrier) to nothing; footnotes are appended without anchors.

interpretation

So long as it contains a detectable amount, the entire mixture or substance is to be weighed when calculating the sentence.

Chapman v. United States — 500 U.S. 453 (1991) · Supreme Court of the United States · 1991 (21usc841: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)

So long as it contains a detectable amount, the entire mixture or substance is to be weighed when calculating the sentence.

PARTIAL_THRESHOLD_TABLE: this entry anchors the § 841(b)(1) drug-specific threshold matrix without pretending that one heroin threshold quote enumerates every listed substance and tier. Under Chapman v. United States (500 U.S. 453 (1991)), "mixture or substance" includes the carrier medium in which the drug is marketed/consumed, but not unusable waste water or packaging containers that must be separated before use.

interpretation

The term does not include LSD in a bot-tie, or LSD in a car, because the drug is easily distinguished from, and separated from, such a “container.”

Chapman v. United States — 500 U.S. 453 (1991) · Supreme Court of the United States · 1991 (21usc841: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)

The term does not include LSD in a bot-tie, or LSD in a car, because the drug is easily distinguished from, and separated from, such a “container.”

PARTIAL_THRESHOLD_TABLE: this entry anchors the § 841(b)(1) drug-specific threshold matrix without pretending that one heroin threshold quote enumerates every listed substance and tier. Under Chapman v. United States (500 U.S. 453 (1991)), "mixture or substance" includes the carrier medium in which the drug is marketed/consumed, but not unusable waste water or packaging containers that must be separated before use.

interpretation

By measuring the quantity of the drugs according to the “street weight” of the drugs in the diluted form in which they are sold, rather than according to the net weight of the active component, the statute and the Sentencing Guidelines increase the penalty for persons who possess large quantities of drugs, regardless of their purity.

Chapman v. United States — 500 U.S. 453 (1991) · Supreme Court of the United States · 1991 (21usc841: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)

By measuring the quantity of the drugs according to the “street weight” of the drugs in the diluted form in which they are sold, rather than according to the net weight of the active component, the statute and the Sentencing Guidelines increase the penalty for persons who possess large quantities of drugs, regardless of their purity.

Rejected in Chapman v. United States (500 U.S. 453 (1991)): Congress had a rational basis for tying penalty tiers to street weight of the mixture or substance containing a detectable amount of the drug.

interpretation

First Amendment freedoms are not infringed by §841, so the vagueness claim must be evaluated as the statute is applied to the facts of this case.

Chapman v. United States — 500 U.S. 453 (1991) · Supreme Court of the United States · 1991 (21usc841: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)

First Amendment freedoms are not infringed by §841, so the vagueness claim must be evaluated as the statute is applied to the facts of this case.

Evaluated as applied to the facts of the case because § 841 implicates no First Amendment freedoms.

interpretation

So long as it contains a detectable amount, the entire mixture or substance is to be weighed when calculating the sentence.

Chapman v. United States — 500 U.S. 453 (1991) · Supreme Court of the United States · 1991 (21usc841: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)

So long as it contains a detectable amount, the entire mixture or substance is to be weighed when calculating the sentence.

Invoked when statutory text of § 841(b) is grievously ambiguous (declined in Chapman where "mixture or substance" was held unambiguous; reinforced in Burrage where "results from" was given its ordinary but-for meaning).