601 U.S. 124
SCOTUS2024Background:
- Petitioner Mark Pulsifer pleaded guilty to distributing ≥50 grams of methamphetamine and faced a 15-year statutory mandatory minimum.
- He sought relief under the sentencing "safety‑valve", 18 U.S.C. §3553(f), which waives statutory minimums if five criteria are met; §3553(f)(1) concerns criminal history.
- §3553(f)(1) requires the court to find the defendant "does not have— (A) more than 4 criminal history points (excluding 1‑point offenses); (B) a prior 3‑point offense; and (C) a prior 2‑point violent offense," each phrase referencing the Sentencing Guidelines.
- The Government read that language as a three‑part checklist (must not have A, must not have B, must not have C); Pulsifer read it to require the combination (ineligible only if he has A and B and C together).
- District Court and the Eighth Circuit adopted the Government’s reading; the Supreme Court granted certiorari and affirmed, holding §3553(f)(1) requires satisfying each of the three separate conditions and that Pulsifer (with two prior 3‑point offenses totaling six points) is ineligible.
Issues:
| Issue | Pulsifer's Argument | United States' Argument | Held |
|---|---|---|---|
| Interpretation of 18 U.S.C. §3553(f)(1): whether "does not have A, B, and C" means lacking the combination of all three vs. lacking each individually | §3553(f)(1) disqualifies only those who have all three items together (A and B and C); otherwise eligible | §3553(f)(1) is a checklist: the prefatory "does not have" distributes to each item, so having any one of A, B, or C makes defendant ineligible | The Court adopted the Government’s reading: defendant must satisfy each condition (no >4 points; no prior 3‑point offense; no prior 2‑point violent offense); Pulsifer ineligible |
Key Cases Cited
- National Assn. of Mfrs. v. Department of Defense, 583 U.S. 109 (2018) (canon against surplusage supports avoiding readings that render a subparagraph meaningless)
- Luna Perez v. Sturgis Public Schools, 598 U.S. 142 (2023) (statutory purpose does not override clear text)
- Encino Motorcars, LLC v. Navarro, 584 U.S. 79 (2018) (context resolves ambiguities about distributed antecedents)
- IBP, Inc. v. Alvarez, 546 U.S. 21 (2005) (meaningful‑variation canon: different words usually signal different meanings)
- Gibbons v. Ogden, 9 Wheat. 1 (1824) (illustrative use of distributed predicates in constitutional text)
- United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (1906) (syllabus disclaimer referenced in opinion preface)