McFadden v. United States

Summarized by:

  • Court: United States Supreme Court
  • Area(s) of Law: Criminal Law
  • Date Filed: June 18, 2015
  • Case #: 14-378
  • Judge(s)/Court Below: THOMAS, J., delivered the opinion of the Court, in which SCALIA, KENNEDY, GINSBURG, BREYER, ALITO, SOTOMAYOR, and KAGAN, JJ., joined. ROBERTS, C. J., filed an opinion concurring in part and concurring in the judgment.
  • Full Text Opinion

Under the Analogue Act, the knowledge requirement is met if the defendant knew the analogue substance was a controlled substance or an analogue, or knew the specific features that made it a controlled substance.

Petitioner was indicted for distribution of bath salts by a federal grand jury. At trial, the district court judge instructed the jury that the Respondent, the United States Government, had to show the Petitioner “knowingly…distributed a mixture or substance that has substantially similar effects on the nervous system as a controlled substance and….[Petitioner] intended [it]…to be consumed by humans.” The Court of Appeals affirmed the instruction reasoning the intent was satisfied if the Petitioner knew the substance he was distributing was going to be consumed by humans.

The U.S. Supreme Court found the intent element was met if a defendant knew the analogue substance was a controlled substance or had the features of a controlled substance. Respondent had to prove one of two mental states, either Petitioner knew he was distributing a substance listed on the drug schedules in the Controlled Substances Act or listed in the Analogue Act, regardless if he knew the specific substance. Or, second, Petitioner knew the specific features of the substance that made it analogous to a substance on the drug schedules. Respondent can prove the intent by either direct or circumstantial evidence. VACATE AND REMAND

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