Walker v. States
Headline: Court declines to review whether drug-sentence weight should include meth lab waste, leaving lower-court rule in place and making outcomes depend on which federal appeals circuit hears the case.
Holding: The Court declined to review the question, leaving the Fifth Circuit’s ruling that counts the total weight of contaminated liquid for sentencing in effect.
- Leaves sentencing based on total weight of contaminated waste in place in this circuit.
- Makes defendants’ sentences vary depending on which federal appeals circuit hears the case.
- Affects meth lab cases where liquids are mostly solvents but contain detectable drugs.
Summary
Background
Three criminal defendants challenged the way courts count the weight of liquid waste left from making methamphetamine when calculating drug sentences. The liquid was a toxic mix of phenylacetone and a small amount of methamphetamine. In two trials a chemist said the liquid was probably leftover waste. In a third case the Government agreed that over 95% of the liquid’s weight was solvents. The Fifth Circuit rejected the argument that only the drug portion should count for sentencing. The denial of review by this Court left that ruling in place.
Reasoning
The main question was whether courts should count the total weight of contaminated waste that contains any detectable controlled drug when applying the Sentencing Guidelines rule §2D1.1. Justice White, joined by Justice Blackmun, wrote that this issue has produced conflicting results among federal appeals courts. Several circuits have favored counting only the drug portion, while others have allowed counting the entire waste weight. The dissent notes the Court has repeatedly declined review of the split in prior cases and argues the high court should decide the issue to produce consistent results.
Real world impact
Because the Supreme Court refused review, the Fifth Circuit’s approach stands for cases in that circuit. The result means a defendant’s sentence can vary simply based on which federal appeals court handles the case. People convicted of drug offenses involving manufacturing waste may face longer or shorter sentences depending on whether a court counts the full weight of the solvent-heavy liquid.
Dissents or concurrances
Justice White would have granted review to resolve the conflict among circuits and to produce uniform sentencing rules across federal appeals courts.
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