Chapman et al. v. United States
500 U.S. 453 (1991)
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Rule of Law:
Under 21 U.S.C. § 841(b), the total weight of a 'mixture or substance containing a detectable amount' of a controlled substance, including the weight of the carrier medium (such as blotter paper for LSD), must be used to determine eligibility for mandatory minimum sentences.
Facts:
- Richard L. Chapman, John M. Schoenecker, and Patrick Brumm sold 10 sheets of blotter paper containing 1,000 doses of lysergic acid diethylamide (LSD).
- The pure LSD on the sheets weighed approximately 50 milligrams.
- The combined weight of the LSD and the blotter paper was 5.7 grams.
- A federal statute imposes a mandatory minimum five-year sentence for distributing more than one gram of a 'mixture or substance' containing a detectable amount of LSD.
- LSD is typically distributed by dissolving the pure drug in a solvent, applying it to a carrier medium like blotter paper, and allowing the solvent to evaporate, leaving the LSD crystals infused in the paper.
Procedural Posture:
- Petitioners Chapman, Schoenecker, and Brumm were convicted in a U.S. District Court (trial court) for selling LSD in violation of 21 U.S.C. § 841(a).
- At sentencing, the District Court calculated the drug weight by including the 5.7-gram weight of the blotter paper, triggering the five-year mandatory minimum sentence.
- Petitioners appealed the sentence to the U.S. Court of Appeals for the Seventh Circuit (intermediate appellate court).
- The Court of Appeals for the Seventh Circuit, sitting en banc, affirmed the District Court's sentencing calculation.
- The U.S. Supreme Court granted certiorari to review the decision of the Seventh Circuit.
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Issue:
Does the phrase 'mixture or substance containing a detectable amount of' lysergic acid diethylamide (LSD) under 21 U.S.C. § 841(b)(1)(B)(v) require the court to include the weight of the blotter paper carrier medium when calculating the total drug quantity for sentencing purposes?
Opinions:
Majority - Chief Justice Rehnquist
Yes, the phrase 'mixture or substance containing a detectable amount of' LSD requires the inclusion of the carrier medium's weight. The plain meaning of 'mixture' encompasses LSD that has been absorbed into blotter paper, as the two components are commingled but do not chemically combine. The statutory structure supports this reading; unlike for drugs such as PCP, Congress did not provide a separate, lower weight threshold for pure LSD, indicating its intent to base sentences on the weight of the entire mixture. Furthermore, Congress adopted a 'market-oriented' approach to sentencing, intending to punish traffickers based on the weight of the drugs in the form they are distributed at the retail level. Including the carrier's weight is rationally related to the legitimate government interest of punishing large-volume drug traffickers and targeting the street-level drug trade.
Dissenting - Justice Stevens
No, the weight of the carrier medium should not be included because the term 'mixture or substance' is ambiguous and the majority's interpretation produces bizarre and inequitable results unintended by Congress. This construction leads to sentencing disparities where a dealer selling a few doses on a heavy carrier (like a sugar cube) could receive a longer sentence than a wholesaler with thousands of doses of pure LSD. This undermines the core congressional goal of promoting sentencing uniformity. The legislative history is silent on this specific issue, and the absurd consequences suggest Congress did not contemplate how LSD is sold and could not have intended for sentences to be dictated by the arbitrary weight of an inert carrier medium rather than the quantity of the illicit drug.
Analysis:
This decision solidifies a 'market-oriented' approach to drug sentencing, emphasizing the weight of the distributable product over the purity of the controlled substance itself. It resolves a circuit split by confirming that the plain language of the statute requires including carrier weight, significantly increasing potential sentences for LSD distributors who use common, relatively heavy mediums like blotter paper or sugar cubes. The ruling underscores the judiciary's deference to congressional sentencing schemes under rational basis review, even when those schemes produce outcomes that appear disproportionate or anomalous in practice.
