DePierre v. United States
564 U.S. 70
| SCOTUS | 2011Background
- Congress imposed mandatory minimums under § 841(b)(1) for cocaine offenses, including 50 grams of cocaine base with a 10-year minimum and 5 grams with a 5-year minimum.
- The ADAA defines cocaine base broadly, covering substances containing cocaine base, which Congress intended to penalize more severely than other cocaine-related substances.
- Guidelines originally mirrored the ADAA’s 100-to-1 ratio but defined cocaine base for guideline purposes as crack; the statutory term’s meaning remained unresolved.
- DePierre was convicted for distributing 50 grams or more of cocaine base; the district court instructed the jury to treat cocaine base as crack cocaine.
- The First Circuit affirmed, holding that cocaine base includes all chemically basic forms, not just crack cocaine.
- The Supreme Court affirmed, holding that cocaine base means cocaine in its chemically basic form, not exclusively crack cocaine.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of cocaine base in § 841(b)(1)(A)(iii) | DePierre: cocaine base means crack cocaine. | United States: cocaine base means chemically basic cocaine (C17H21N04). | Cocaine base means chemically basic cocaine. |
| Relation between clause (ii) and clause (iii) | Crack-only interpretation fits text of § 841(b)(1). | Text supports broader base-form interpretation; not limited to crack. | Clause (iii) covers substances containing chemically basic cocaine, not just crack. |
| Role of guidelines vs. statute in interpreting cocaine base | Guidelines definition of cocaine base should govern statute. | Legislative text controls; guidelines are not binding for § 841(b)(1). | Statutory text governs; guidelines do not control § 841(b)(1) meaning. |
| Lenity and ambiguity | If ambiguous, lenity should resolve in defendant’s favor. | Statute is not ambiguous; lenity not warranted. | Lenity does not apply; statute unambiguous in favor of base-form reading. |
Key Cases Cited
- Rodriguez, 553 U.S. 377 (2008) (textual fidelity; avoid reading text against its plain meaning)
- Kimbrough v. United States, 552 U.S. 85 (2007) (Deal with sentencing discretion and statutory text)
- Neal v. United States, 516 U.S. 284 (1996) (deference to guideline interpretations not presumed for statutes)
- Sosa v. Alvarez-Machain, 542 U.S. 692 (2004) (statutory interpretation cautious about divergent language)
- Deal v. United States, 508 U.S. 129 (1993) (congress sometimes uses different language to convey same meaning)
- Oncale v. Sundowner Offshore Services, 523 U.S. 75 (1998) (statutory purpose and plain meaning considerations)
- Reno v. Koray, 515 U.S. 50 (1995) (statutory interpretation and lenity considerations)
- Santos, 553 U.S. 507 (2008) (rule of lenity in ambiguous criminal statutes)
- Public Lands Council v. Babbitt, 529 U.S. 728 (2000) (statutory interpretation and purpose over textual anomalies)