Pulsifer v. United States, 601 U.S. 124

Mark Pulsifer pleaded guilty to distributing ≥50 grams of methamphetamine and faced a 15-year statutory mandatory minimum.
18 U.S.C. §3553(f) (the “safety valve”) permits sentencing without regard to mandatory minima if five criteria are met; (f)(1) concerns criminal history.
After the First Step Act (2018) §3553(f)(1) reads that the court must 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 (points as determined under the Guidelines).
Government: Pulsifer’s two prior 3‑point convictions gave him 6 points, so he failed (A) and (B); he was thus ineligible. Pulsifer: eligibility is lost only if the defendant has the combination of A, B, and C together.
District Court and the Eighth Circuit agreed with the Government; the Supreme Court granted certiorari and affirmed, holding the provision is a three‑part checklist—defendant must satisfy each subpart individually.

Issue	Pulsifer's Argument	United States' Argument	Held
How to interpret §3553(f)(1): does "does not have (A), (B), and (C)" mean (i) only the combined presence of all three bars relief, or (ii) possession of any one of the three bars relief?	"And" ties A, B, C into a single combined disqualifier—relief barred only if defendant has all three.	"Does not have" distributes to each item: defendant must not have A, and must not have B, and must not have C; possession of any one bars relief.	The Court adopted the Government’s reading: §3553(f)(1) is an eligibility checklist—defendant must lack each of A, B, and C individually to get safety‑valve relief.

United States v. Detroit Timber & Lumber Co., 200 U.S. 321 (syllabus form does not belong to the Court’s opinion)
National Assn. of Manufacturers v. Department of Defense, 583 U.S. 109 (canon against surplusage applied where a reading would render a subparagraph meaningless)
Encino Motorcars, LLC v. Navarro, 584 U.S. 79 (interpretation can hinge on ordinary meaning of connecting words)
IBP, Inc. v. Alvarez, 546 U.S. 21 (meaningful‑variation canon—different words likely mean different things)
Wisconsin Central Ltd. v. United States, 585 U.S. 274 (use of different terms in companion statutes may indicate different meanings)
Luna Perez v. Sturgis Public Schools, 598 U.S. 142 (purpose cannot override clear statutory text)