## Facts

- Richard Chapman and a codefendant sold 10 sheets of LSD-infused blotter paper totaling 1,000 doses, violating 21 U.S.C. § 841(a).
- The pure LSD weighed about 50 milligrams, but the LSD plus blotter paper weighed 5.7 grams.
- For sentencing, the government and district court used the 5.7-gram combined weight as the relevant “mixture or substance containing a detectable amount” of LSD.
- Because the combined weight exceeded 1 gram, § 841(b)(1)(B) triggered a 5-year mandatory minimum sentence; the same weight also drove the Sentencing Guidelines base offense level.
- The Seventh Circuit affirmed the convictions and sentences; the Supreme Court granted review.

## Issues

1. Whether 21 U.S.C. § 841(b)(1)(B) requires inclusion of the weight of the carrier medium (blotter paper) when calculating the weight of a “mixture or substance containing a detectable amount” of LSD for mandatory minimum sentencing.
2. Whether counting the carrier’s weight for LSD violates equal protection principles embodied in the Fifth Amendment’s Due Process Clause (and related proportionality objections).

## Decision

- The Supreme Court affirmed, holding 7–2 that § 841(b)(1)(B) requires counting the weight of the LSD and the carrier medium.
- The Court held that LSD on blotter paper qualifies as a “mixture or substance containing a detectable amount” of LSD, so the entire combined weight is used for the statutory threshold and Guidelines calculations.
- The Court rejected the constitutional challenge, concluding that Congress’s method is rational and not unconstitutional.

## Legal Principles

- Under § 841(b)(1), drug quantity for mandatory minimums is generally determined by the total weight of a “mixture or substance containing a detectable amount” of the controlled substance, not by pure-drug weight.
- LSD distributed on an ingestible carrier (such as blotter paper) may be treated as a “mixture or substance,” so the carrier’s weight is included in the total.
- Congress may use a market-based sentencing measure tied to the total amount of drug in the form distributed to consumers; this approach satisfies rational basis review under the Fifth Amendment’s Due Process Clause.
- A mandatory minimum sentence based on the combined weight of LSD and its carrier is not unconstitutional merely because it can produce disparities across carriers or across different drugs.

## Conclusion

The Court held that when LSD is sold on blotter paper, § 841(b)(1)(B) requires using the combined weight of the LSD and the paper to determine mandatory minimum sentencing, and it upheld this sentencing method against Fifth Amendment equal protection and related proportionality objections.


Chapman v. United States, 500 U.S. 453 (1991)