## Facts

- Police found J.H. dead in her home near drug paraphernalia and a bag containing 0.58 grams of fentanyl.
- Text messages on J.H.’s phone suggested she had attempted to buy or had bought drugs from Jurmaine A. Jeffries earlier that day.
- Officers, posing as J.H., texted Jeffries to request more drugs; Jeffries arrived about 45 minutes later and was arrested.
- A search recovered multiple bags of fentanyl from Jeffries’s car and person, cash, and a phone containing the relevant messages.
- At trial, medical experts testified J.H.’s fentanyl level was well above lethal levels and that no other anatomical cause explained her death.
- Jeffries requested a jury instruction requiring the government to prove the death was a natural and foreseeable result of his conduct (proximate cause); the court refused.
- The jury was instructed only on but-for causation and found the “death results” enhancement proven.

## Issues

1. Whether 21 U.S.C. § 841(b)(1)(C)’s “if death or serious bodily injury results from the use of such substance” requires proof of proximate cause in addition to but-for causation.

## Decision

- The Sixth Circuit reversed the district court’s order granting a new trial under Rule 33.
- The court held § 841(b)(1)(C) requires proof of but-for causation only, not proximate causation, for the “death results” enhancement.
- The case was remanded for sentencing consistent with the jury’s verdict.

## Legal Principles

- Under § 841(b)(1)(C), the “results from” language requires that the victim’s death would not have occurred but for the victim’s use of the controlled substance distributed by the defendant.
- Supreme Court precedent interpreting the same statutory phrase establishes a but-for causation requirement and does not add a foreseeability or proximate-cause element.
- Courts should not add a proximate-cause requirement absent statutory text indicating Congress intended that limitation.

## Conclusion

The Sixth Circuit concluded that the enhanced penalty for drug distribution “resulting in death” under § 841(b)(1)(C) turns on but-for causation alone; because the jury was properly instructed on that standard, the district court erred in ordering a new trial for lack of a proximate-cause instruction.


United States v. Jeffries, 958 F.3d 517 (6th Cir. 2020)