Supreme Court rejects expansive interpretation of Trump's drug sentencing reform

 March 18, 2024

The Supreme Court shot down a liberal interpretation of President Trump's criminal justice reform law, denying a drug dealer's request for a shortened sentence. 

The defendant, Iowa man Mark Pulsifier, sought a reduced sentence under the First Step Act, a criminal justice reform law enacted by President Trump.

Pulsifier was facing a minimum of 15 years in prison after pleading guilty to distributing 50 grams of methamphetamine.

The court debated the conditions for the so-called "safety valve," which allows courts to reduce mandatory minimum sentences for "low-level" offenders.

Supreme Court's drug ruling

The controversy turned on the use of the conjunction "and." The law says that the safety valve is available to a defendant who "does not have" three different conditions relating to criminal history, labeled A, B, and C.

Pulsifier's criminal history met two of the three conditions. His lawyers argued that "and" in the statute means that he needs to meet all three conditions before losing eligibility.

But the court saw it differently. In a 6-3 opinion authored by liberal justice Elena Kagan, the Supreme Court ruled that the language functions like an "eligibility checklist, and demands that a defendant satisfy every one of its conditions.”

"A defendant is eligible for safety-valve relief only if he satisfies each of the paragraph’s three conditions," wrote Kagan.

"He cannot have more than four criminal history points. He cannot have a prior three-point offense. And he cannot have a prior two-point violent offense. Because Pulsifer has two prior three-point offenses totaling six points, he is not eligible."

Gorsuch joins the liberals

The dissent was written by conservative Neil Gorsuch, joined by liberals Sonia Sotomayor and Ketanji Brown Jackson.

Gorsuch complained that the court's interpretation "guarantees that thousands more people in the federal criminal justice system will be denied a chance—just a chance—at an individualized sentence."

Further, Gorsuch accused the majority of disregarding the "natural" reading of the statute. But Kagan argued that Pulsifier's interpretation of the conjunction "and" rendered part "A" meaningless.

If a defendant "has a three-point offense under Subparagraph B and a two-point offense under Subparagraph C, he will always have more than four criminal-history points under Subparagraph A," she noted. Congress wouldn't include an factor if it had no effect, she concluded.

Furthermore, adopting Pulsifier's reading would create a mismatch between a defendant's conduct and his eligibility for relief.

For example, a defendant "with numerous violent three-point offenses could get relief because he happens not to have a two-point offense," she argued.

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