United States v. Hatfield

591 F.3d 945 (2010)

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Nature of the Case

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Facts

Ds sold illegal drugs to four different users who after ingesting them died. There was also a serious bodily injury of a fifth user of Ds’ drugs. P prosecuted Ds for conspiracy to burglarize pharmacies, and to distribute controlled substances (including morphine, methadone, oxycodone, fentanyl, alprazolam, cocaine, and hydrocodone), the use of which resulted in death or serious bodily injury. The trial judge issues jury instructions by stating that the jury had 'to determine whether P has established, beyond a reasonable doubt, that the victims died or suffered serious bodily injury, as a result of ingesting a controlled substance or controlled substances distributed by Ds. The court then stated that the controlled substances distributed by Ds had to have been 'a factor that resulted in death or serious bodily injury,' and that although they 'need not be the primary cause of death or serious bodily injury' they 'must at least have played a part in the death or in the serious bodily injury.' Ds' lawyer asked that the addition, suggested by the prosecutor, be stricken as a confusing gloss on 'results from.' The judge refused. A jury convicted Ds of conspiracy to burglarize pharmacies, and to distribute controlled substances (including morphine, methadone, oxycodone, fentanyl, alprazolam, cocaine, and hydrocodone), the use of which resulted in death or serious bodily injury. Ds appealed.