United States v. Clifford Reed, 20-3054

In 2016 Clifford Reed sold a 996‑gram brick of heroin laced with fentanyl and carfentanil; he sought to buy more carfentanil and was arrested.
Reed pleaded guilty to three §841(a)(1) counts charging distribution of mixtures containing heroin, fentanyl, and carfentanil (thresholds charged based on mixture weight).
The PSR assigned the entire mixture weight to the drug producing the highest offense level (carfentanil), yielding a base offense level 32 and a Guidelines range of 168–210 months; statutory minimum was 120 months.
Reed introduced an expert purity analysis showing only small percentages of each controlled substance and argued Guidelines and statutory penalties should be based on pure‑drug weight; he also asserted an as‑applied due process challenge.
The district court ruled Chapman v. United States controlled, applied mixture (street) weight, reduced Reed’s criminal history and varied downward, and imposed the 120‑month statutory minimum.
On appeal Reed challenged the mixture‑weight rule and §841(b)’s constitutionality; the Seventh Circuit affirmed, holding Chapman controls and the sentencing scheme is rational and constitutional.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §841’s "mixture or substance" is measured by total mixture (street) weight or pure controlled‑substance weight	Gov't: mixture (street) weight applies per Chapman	Reed: use actual pure‑drug weight because controlled substances were a tiny percent	Court: affirms Chapman—use mixture weight
Whether §841(b) is unconstitutional (Fifth Amendment due process) as applied to low‑purity mixtures	Gov't: statute is rational, targets street traffickers, constitutional	Reed: statute is irrational and treats dissimilarly situated defendants the same	Court: statute is rational and constitutional; Chapman forecloses challenge
Whether the court should depart from or overrule Chapman	Gov't: bound by controlling Supreme Court precedent	Reed: Chapman is wrong, unfair, and undermined by later cases	Court: cannot overrule Supreme Court; follow Chapman (Rodriguez de Quijas, Cross)
Whether Guidelines should be based on pure weight and whether any Guidelines error matters to sentence	Gov't: statutory minimum governs sentencing regardless of Guidelines	Reed: Guidelines should be lower based on purity	Court: even if Guidelines suggested less, statutory minimum controls (Koons)

Chapman v. United States, 500 U.S. 453 (1991) ("mixture or substance" means street‑weight mixtures; scheme upheld as rational)
Cross v. United States, 892 F.3d 288 (7th Cir. 2018) (lower courts must follow Supreme Court precedent even if unpersuasive)
Rodriguez de Quijas v. Shearson/American Express, Inc., 490 U.S. 477 (1989) (appellate courts should follow controlling Supreme Court cases and leave overruling to that Court)
Koons v. United States, 138 S. Ct. 1783 (2018) (statutory minimum sentences govern even if Guidelines recommend lower)