Wednesday, November 15, 2006

In § 846 Conspiracy, Drug Quantity Aggregation Proper to Determine Penalty under § 841(b)

United States v. Pressley, Docket No. 05-2487-cr (L) (2d Cir. Nov. 14, 2006) (Cardamone, Walker, Straub) (per curiam): In United States v. Harrison, 241 F.3d 289 (2d Cir. 2001), the Circuit ruled that where a defendant is convicted of two or more separate substantive counts of drug distribution, in violation of 21 U.S.C. § 841(a), the quantity of drugs distributed in the separate counts may not be aggregated for purposes of determining the proper penalty under the weight-driven graduated scheme of § 841(b). In this case, Pressley was convicted of conspiring to distribute 1 kilogram or more of heroin, in violation of 21 U.S.C. § 846, and thus seemingly subject to the harsh penalties of § 841(b)(1)(A) (mandatory minimum of 10 years and maximum of life imprisonment). He relied on Harrison to argue, however, that he should be punished under § 841(b)(1)(c) (carrying no mandatory minimum penalty and a 20-year maximum) because although the decade-long conspiracy encompassed over 1 kilogram of heroin, no single transaction exceeded this quantity. Rather, the 1-kilo threshold represented the aggregate of thousands of street-level sales of very small quantities.

The Circuit rejects this argument, finding that "[b]ecause a conspiracy is a single, unified offense, it constitutes "a violation" for purposes of § 841(b). Op.5; see Op. 4, quoting 21 U.S.C. § 841(b) ("In the case of a violation of subsection (a) of this section involving. . . 1 kilogram or more ... of heroin ... such person shall be sentenced to a term of imprisonment which may not be less than 10 years or more than life.") (emphases in Opinion). The Court distinguishes Harrison on this basis. There, each separate substantive drug distribution count constitutes a separate "violation" within the meaning of § 841(b). Here, in contrast, the single conspiracy count is itself the "violation" under § 841(b), a "violation" that "'involves' the aggregate quantity of all the subsidiary transactions attributable to that particular member" of the conspiracy. Op.5.

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