United States v. David Piaquadio, 20-2841

In a non-jury trial, David Piaquadio was convicted on drug counts including Count Four: causing serious bodily injury by distributing fentanyl, triggering the 21 U.S.C. § 841(b)(1)(C) 20-year mandatory minimum.
Victim Joshua Moroschok received a fentanyl patch from Piaquadio, allegedly extracted about one-quarter of the patch, heated it, and injected the extract; he was later found unconscious with a syringe and a spoon; the spoon tested positive for fentanyl.
First responders observed shallow breathing and an oxygen saturation of 75%; paramedics administered naloxone, after which Moroschok improved and was discharged the same night.
Emergency physician Dr. Doan testified fentanyl is 100–400 times more potent than heroin/oxycodone and that injecting even a small portion of a patch posed a grave risk of death; defense expert downplayed life‑threatening risk but acknowledged danger from injected patch material.
The District Court credited the government witnesses and Dr. Doan, found fentanyl use caused a medical emergency posing a substantial risk of death, and applied the enhanced penalty; Piaquadio appealed arguing insufficient evidence of but‑for causation and lack of proof of a substantial risk of death.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that Piaquadio’s distribution of the fentanyl patch was the actual (but‑for) cause of the victim’s serious bodily injury	Piaquadio: evidence does not show but‑for causation; other opioids (heroin/oxycodone) and lack of lab proof of fentanyl make causation uncertain	Government: district court credited victim’s admissions, physical evidence (patch material on spoon), and expert testimony linking injected patch material to the emergency	Affirmed — substantial evidence supports that Piaquadio’s distribution led to the overdose and serious bodily injury (actual cause)
Whether victim suffered serious bodily injury (substantial risk of death) from the fentanyl injection	Piaquadio: quick recovery and short hospital stay show no substantial risk of death; expert testimony was general and did not isolate fentanyl as the sole cause	Government: eyewitness observations, very low oxygen saturation, naloxone response, and expert opinion about fentanyl potency show a substantial risk of death	Affirmed — court found the evidence and expert opinion established a grave danger/substantial risk of death, satisfying serious bodily injury requirement

United States v. Gonzalez, 905 F.3d 165 (3d Cir. 2018) (discusses but‑for causation standard in enhanced drug‑penalty context)
United States v. Lewis, 895 F.3d 1004 (8th Cir. 2018) (overdose creating significant risk of death qualifies as serious bodily injury)
United States v. Bornman, 559 F.3d 150 (3d Cir. 2009) (standard for reviewing sufficiency of the evidence)
United States v. Delerme, 457 F.2d 156 (3d Cir. 1972) (clear‑error review for factual findings in non‑jury trials)
United States v. Gambone, 314 F.3d 163 (3d Cir. 2003) (appellate court must not reweigh evidence or assess witness credibility)