Fifth Amendment Due Process / Equal Protection challenge to carrier-medium weight sentencing (Chapman)

DEFENSE · 21usc841:x-due-process-arbitrary-sentence

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.

Exact element source

1 gram or more of a mixture or substance containing a detectable amount of lysergic acid diethylamide (LSD);
Source: docroot/ir/usc/title21.jsonl#title21_sec841; Unicode character offsets [5386:5494] (end exclusive); SHA-256 ebaba73bf6e21a591f44bf851f24a052a5687813c505030cd9483e17753e9420.

Routes and case patterns

Curated routes and observed case patterns
RouteDefinitionMerits instance blocksDistinct merits casesExamples (up to 3 cases per count group)
_whole
accepted; provisional (1 case)
The element is decided as a whole: the reasoning turns on no narrower doctrinal sub-question that distinguishes it from any other application of this element.0
Satisfied 0; not satisfied 0; excluded context 1
0

Used only in non-merits blocks (1).

Excluded context examples:

Chapman v. United States — 500 U.S. 453 (1991) · Supreme Court of the United States · 1991 — not · law (21usc841: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed) · applied/procedural · not counted
Pattern: rational-basis/street-weight-penalty-scheme

How courts decided this element

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopePatternExact source quotations
Chapman v. United States — 500 U.S. 453 (1991) · Supreme Court of the United States · 1991 — not · law (21usc841: author: Fable · historical QA: PASS (QA2, neov2/qa/cases-QA2.md) · changed after review; current content not independently reviewed)Fifth Amendment Due Process / Equal Protection challenge to carrier-medium weight sentencing (Chapman)not
Excluded from merits counts
applied / procedural

basis: law; claim: (a),(b)(1)(B)(v)

Fifth Amendment due-process/equal-protection facial challenge to weighing the carrier; hypotheticals about very heavy carriers do not help defendants who used the standard one.
rational-basis/street-weight-penalty-scheme
Petitioners appealed, claiming that the blotter paper is only a carrier medium, and that its weight should not be included in the weight of the drug for sentencing purposes.
Source: docroot/ir/caselaw/us_500.jsonl#/us/500/0453-01; Unicode character offsets [1325:1498] (end exclusive); SHA-256 9c5fd40cbce1f1caf4effb469b4d262677c3bae7a486aaca29dd0c70e05d713c.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

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.
Source: docroot/ir/caselaw/us_500.jsonl#/us/500/0453-01; Unicode character offsets [18564:18899] (end exclusive); SHA-256 9c5fd40cbce1f1caf4effb469b4d262677c3bae7a486aaca29dd0c70e05d713c.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

We find that Congress had a rational basis for its choice of penalties for LSD distribution.
Source: docroot/ir/caselaw/us_500.jsonl#/us/500/0453-01; Unicode character offsets [18209:18301] (end exclusive); SHA-256 9c5fd40cbce1f1caf4effb469b4d262677c3bae7a486aaca29dd0c70e05d713c.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations

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.
Source: docroot/ir/caselaw/us_500.jsonl#/us/500/0453-01; Unicode character offsets [18564:18899] (end exclusive); SHA-256 9c5fd40cbce1f1caf4effb469b4d262677c3bae7a486aaca29dd0c70e05d713c.

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.