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The safety-valve provision, 18 U. S. C. §3553(f ), offers some defendants convicted of drug offenses an escape from otherwise applicable mandatory minimums. A court is to sentence a defendant “without regard to any statutory minimum” if it finds that five criteria are met. Three of the criteria focus on characteristics of the offense in particular, whether the defendant used violence; whether the crime resulted in death or serious injury; and whether the defendant acted as a ringleader. One of the criteria addresses the defendant’s cooperation with the Government. See §3553(f )(5). And one-the first listed and the most relevant here-concerns the defendant’s criminal history. In the First Step Act of 2018, Congress relaxed the safety-valve provision’s criminal-history requirement, enabling defendants with more significant criminal records to qualify. Paragraph (f )(1) is met if “the court finds at sentencing” that: the defendant does not have- (A) more than 4 criminal history points, excluding any criminal history points resulting from a 1-point offense, as determined under the sentencing guidelines; (B) a prior 3-point offense, as determined under the sentencing guidelines; and (C) a prior 2-point violent offense, as determined under the sentencing guidelines. D pled guilty in 2020 to distributing at least 50 grams of methamphetamine. He faced a mandatory minimum of 15 years in prison unless the safety-valve provision was applicable. P claimed it did not because D could not meet its criminal-history requirement. D had two relevant prior convictions, each for a three-point offense putting him over the “more than 4 criminal history points,” as specified in Subparagraph A. D pointed out that his criminal record lacked a “2-point violent offense,” as specified in Subparagraph C. In his reading of the statute, only the combination of the items listed in the three subparagraphs could prevent him from getting safety-valve relief. The District Court ruled that a defendant is “ineligible for safety valve” relief if he has any of the “three things” specified in Paragraph (f )(1). The Court of Appeals for the Eighth Circuit affirmed. The court stated that the phrase “the defendant does not have (A), (B), and (C)” might be read in two different ways. It could mean that the defendant does not have the combination of the “three elements listed in (A), (B), and (C),” as D urges. Or it could mean that the defendant does not have every one of those elements-in other words, that he does not have (A), does not have (B), and does not have (C). The court found a “strong textual basis” to prefer P’s reading. The court concluded that D could not escape a mandatory minimum with a pair of three-point offenses; it was simply “immaterial” that he did not also “have a prior two-point violent offense.” D appealed.

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