Chapman v. United States

1991-05-30

Headline: Ruling upholds using blotter-paper weight for LSD counts, affirming mandatory minimum sentences and making it easier for prosecutors to reach statutory weight thresholds for people who sell LSD on carrier mediums.

Holding: The Court held that when LSD is sold on carriers like blotter paper, courts must count the total weight of the carrier plus the drug, allowing mandatory minimum sentences when statutory weight thresholds are met.

Real World Impact:

Carrier weight like blotter paper counts toward LSD sentencing and can trigger mandatory minimums.
Sellers using heavier carriers may receive much longer sentences than those selling pure LSD.
Sellers can reduce exposure by choosing lighter carriers, per the opinion.

Topics: drug sentencing, LSD distribution, mandatory minimums, sentencing guidelines, statutory interpretation

Summary

Background

Three men were convicted for selling ten sheets of blotter paper containing LSD (about 1,000 doses). The district court counted the combined weight of the paper and drug (5.7 grams) and imposed five-year mandatory minimum sentences, even though the pure LSD weighed about 50 milligrams. The defendants appealed, the Seventh Circuit sitting en banc affirmed, and the Supreme Court granted review and now affirms.

Reasoning

The Court addressed whether the law’s phrase “mixture or substance containing a detectable amount” requires weighing the carrier with the drug. The Justices read the statute literally, found the Sentencing Guidelines used similar language, and noted Congress knew how to require pure-drug weights when it wanted to. The Court also concluded Congress had a rational basis for punishing by the total ‘‘street weight’’ of what is sold. The Court rejected the defendants’ equal-protection/due-process and vagueness challenges.

Real world impact

Because carrier materials like blotter paper are counted, many sellers who distribute LSD on paper or other media may hit statutory weight thresholds and face mandatory minimums. The opinion notes that sellers choose carriers and could reduce exposure by using lighter carriers. Congress considered but did not enact bills to exclude carriers, so the ruling stands as the law unless changed by new legislation.

Dissents or concurrances

Justice Stevens, joined by Justice Marshall, dissented, warning that the majority’s construction produces bizarre sentencing disparities, conflicts with sparse legislative history, and undermines the Sentencing Guidelines’ goal of uniformity.