## Facts

- Rex I. Hatfield and Everly K. Hatfield operated a scheme involving burglarizing pharmacies and distributing the stolen controlled substances.
- A jury found them guilty of conspiring to burglarize pharmacies under 18 U.S.C. § 2118(b), (d) and conspiring to distribute controlled substances under 21 U.S.C. §§ 841(a)(1), (b)(1)(C), and 846.
- The controlled substances included morphine, methadone, oxycodone, fentanyl, alprazolam, cocaine, and hydrocodone.
- The government alleged that use of drugs distributed by the defendants caused four user deaths and one user’s serious bodily injury, triggering the enhanced penalty in 21 U.S.C. § 841(b)(1)(C).
- The evidence tying the defendants’ drugs to the deaths and injury was characterized as strong but not conclusive, including uncertainty about other substances the users may have taken.

## Issues

1. Whether the district court misstated the causation requirement under 21 U.S.C. § 841(b)(1)(C) by instructing that the defendants’ drugs need only have been “a factor” that “played a part” in death or serious bodily injury and need not have been the “primary cause.”
2. Whether any instructional error on causation was harmless given the record and the life sentences imposed under the § 841(b)(1)(C) enhancement.

## Decision

- The Seventh Circuit affirmed the convictions for conspiracy to burglarize pharmacies and for drug-distribution conspiracy without the death/serious-bodily-injury enhancement.
- The court reversed the convictions and special findings tied to the four deaths and one serious bodily injury.
- The court vacated the life sentences imposed under § 841(b)(1)(C) and remanded for resentencing on the remaining counts.
- The court held the causation instruction was erroneous and prejudicial as to the enhanced-penalty determinations.

## Legal Principles

- Under 21 U.S.C. § 841(b)(1)(C), the enhanced penalty applies only if death or serious bodily injury “results from” the use of the distributed controlled substance, requiring a genuine causal connection between the substance and the outcome.
- A jury instruction that equates “results from” with the substance being merely “a factor” that “played a part,” and that it need not be the “primary cause,” risks diluting the statutory causation requirement.
- When the evidentiary link between the distributed drug and death or injury is uncertain, an imprecise causation instruction is more likely to affect the verdict and will not be treated as harmless error.
- Instructional error affecting special findings that increase statutory penalties requires reversal of those findings and vacatur of the resulting enhanced sentences, even if the underlying convictions remain supported.

## Conclusion

The Seventh Circuit left intact the Hatfields’ core conspiracy convictions but reversed the death and serious-bodily-injury findings and vacated the life sentences because the jury was instructed on an overly permissive causation standard that could allow enhancement without the required causal link demanded by § 841(b)(1)(C).


United States v. Hatfield, 591 F.3d 945 (7th Cir. 2010)