United States v. Jurmaine Jeffries
958 F.3d 517
| 6th Cir. | 2020Background
- Victim J.H. was found dead with fentanyl present; medical experts testified the level was lethal.
- Text messages linked J.H. to Jurmaine Jeffries, who was arrested near her home with multiple separately packaged bags of fentanyl and cash.
- Jeffries was charged with possession with intent to distribute and distribution resulting in death under 21 U.S.C. § 841(a)(1) and (b)(1)(C).
- At trial the district court instructed the jury using a but‑for causation standard; the jury convicted and applied the § 841(b)(1)(C) enhancement.
- The district court later granted Jeffries a new trial, concluding it had erred by not instructing on proximate causation; the government appealed.
- The Sixth Circuit reversed, holding § 841(b)(1)(C) requires but‑for causation only, and remanded for sentencing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 841(b)(1)(C) requires proximate (legal) causation in addition to but‑for causation | Jeffries: statute ambiguous; common‑law proximate‑cause principle applies; rule of lenity favors requiring proximate cause | Government: "results from" means death must be caused by use of the drug (but‑for causation suffices); statute speaks to the link between drug use and death, not foreseeability | Held: only but‑for causation required; proximate causation not necessary |
| Whether Burrage controls the level of causation | Jeffries: Burrage left proximate‑cause question open and relied on common law; supports requiring proximate cause | Government: Burrage interpreted "results from" as requiring but‑for causation and did not impose proximate cause | Held: Burrage requires but‑for causation and does not mandate proximate cause |
| Whether district court erred by consulting background criminal‑law principles to impose proximate cause | Jeffries: where statute ambiguous, background rules apply | Government: phrase is unambiguous in context; Congress targeted deaths from use of Schedule I/II drugs, so proximate causation is unnecessary | Held: phrase not ambiguous in context; district court erred to import proximate‑cause requirement |
| Role of precedent (Martinez and sister circuits) | Jeffries: Martinez (6th Cir.) and Supreme Court cert grant show ambiguity; other circuits' analyses are thin | Government: multiple circuits hold proximate cause not required; statute's ordinary meaning controls | Held: Martinez distinguished; majority follows post‑Burrage circuit consensus that but‑for causation suffices |
Key Cases Cited
- Burrage v. United States, 571 U.S. 204 (2014) (Supreme Court held "results from" requires but‑for causation; declined to decide proximate cause question)
- Martinez v. United States, 588 F.3d 301 (6th Cir. 2009) (6th Cir. applied proximate‑cause standard under a similar "results in death" enhancement in the health‑care‑fraud statute)
- Paroline v. United States, 572 U.S. 434 (2014) (discussed proximate cause as foreseeability and scope of risk in criminal causation)
- Patterson v. United States, 38 F.3d 139 (4th Cir. 1994) (early circuit decision holding proximate causation not required for § 841 enhancement)
- Harden v. United States, 893 F.3d 434 (7th Cir. 2018) (post‑Burrage circuit decision holding but‑for causation suffices)
- Alvarado v. United States, 816 F.3d 242 (4th Cir. 2016) (post‑Burrage decision concluding proximate causation not required)