Neal v. United States

Background

A man named Meirl Neal was convicted after selling 11,456 doses of LSD on blotter paper, with the combined weight of the blotter and drug totaling 109.51 grams. Under the law, selling 10 grams or more of a mixture containing LSD triggers a 10-year mandatory minimum prison term. The Sentencing Commission later changed the Guidelines to treat each dose as 0.4 milligrams, which would have attributed 4.58 grams to Neal and produced a much lower Guidelines range.

Reasoning

The Court addressed whether the Commission’s dose-based method replaces the statutory rule used to calculate mandatory minimums. The Justices relied on their earlier decision in Chapman, which held that the statute requires weighing the entire mixture or substance (here, the blotter paper with absorbed LSD). The Court concluded the Commission’s new dose rule was meant to set guideline offense levels, not to change the statute, and that it cannot override the Court’s statutory interpretation. The Court therefore kept its prior reading of the statute and affirmed the lower court’s approach.

Real world impact

Because the Court adhered to Chapman, federal courts must count the actual weight of blotter paper with LSD when determining statutory mandatory minimums, even if the Guidelines use a dose-based estimate for offense levels. The decision leaves intact higher mandatory sentences for many LSD-on-carrier cases and limits the Sentencing Commission’s ability to alter statutory minimum calculations.