Pulsifer v. United States
In brief
To receive safety-valve relief, a defendant must have no more than four criminal-history points, no prior three-point offense, and no prior two-point violent offense.
- Where it stands
- Decided
Decided 6-3 · March 15, 2024 · Opinion by Justice Kagan
- What it’s about
- The Court held that a defendant seeking relief from a federal mandatory minimum under the safety-valve law must meet all three criminal-history requirements in 18 U.S.C. § 3553(f)(1).
- Who it affects
- The decision narrows who can avoid a mandatory minimum sentence under this part of the safety-valve law. For example, a person with a prior three-point offense cannot receive this relief even if they meet the other two criminal-history conditions.
Summary: written with AI from the case record.
What it's about
Because Mark Pulsifer had prior three-point offenses, he was ineligible for that relief, and the Court affirmed the Eighth Circuit in favor of the United States.
The case concerns how broadly the First Step Act of 2018 expanded access to individualized sentencing instead of mandatory minimums.
Question presented
Must a defendant show he does not meet any of the criteria listed in 18 U.S.C. § 3553(f) to qualify for a sentence lower than the statutory minimum?
What the Court decided
Holding
A defendant facing a mandatory minimum sentence is eligible for safety-valve relief under 18 U. S. C. §3553(f)(1) only if he satisfies each of the provision’s three conditions—or said more specifically, only if he does not have more than four criminal-history points, does not have a prior three-point offense, and does not have a prior two-point violent offense. 39 F. 4th 1018, affirmed.
- Result
- Affirmed
The vote
From the opinions
“only if he does not have more than four criminal-history points, does not have a prior three-point offense, and does not have a prior two-point violent offense.”
“This dispute concerns who is eligible for individualized sentencing and who remains subject to mandatory minimums after the First Step Act.”
What's next
Federal courts will apply the Court's three-part reading of the criminal-history rule in future safety-valve sentencing requests. Pulsifer's case remains resolved in favor of the United States.
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
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AI analysis generated: Opinion Summary
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Brief added: Petition
Brief added: Questions Presented
More questions
- What did the Supreme Court rule in Pulsifer v. United States?
- The Court said defendants must satisfy all three criminal-history conditions to qualify for safety-valve relief from a mandatory minimum sentence.
- Who won Pulsifer v. United States?
- The United States won. The Court affirmed the Eighth Circuit and concluded that Pulsifer was ineligible for safety-valve relief.
- What does Pulsifer mean for defendants with prior three-point offenses?
- They cannot receive this safety-valve relief, even if they meet the other two criminal-history conditions.
- How will lower courts apply Pulsifer next?
- They must require defendants seeking safety-valve relief to meet each of the three criminal-history conditions.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.