Pulsiferv.United States
Mark Pulsifer pleaded guilty to distributing at least fifty grams of methamphetamine and faced a fifteen-year mandatory minimum sentence. He sought safety-valve relief under a federal sentencing statute, arguing that the statutory disqualification applied only when a defendant had the listed combination of criminal-history features. The Supreme Court of the United States rejected that reading. It held that the statute uses separate disqualifying conditions: a defendant is ineligible if he has more than four qualifying criminal-history points, a prior three-point offense, or a prior two-point violent offense. Because Pulsifer had more than four points and prior three-point offenses, he could not receive safety-valve relief even though he lacked a prior two-point violent offense. The Court affirmed the judgment below. A dissent argued that the statutory text was ambiguous and that the Court should have resolved the uncertainty in favor of access to relief from mandatory minimum sentences.
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