Pulsifer v. United States

The Supreme Court ruled 6-3 that a defendant is only eligible for 'safety valve' relief if they satisfy each of the three criminal history conditions listed in the law. The Court decided that the word 'and' in the statute creates a checklist, meaning a defendant is disqualified if they meet even one of the listed criteria. This decision affirmed the lower court's ruling against Mark Pulsifer, who had argued he should be eligible because he did not meet all three criteria at once.

This ruling makes it harder for nonviolent drug offenders to avoid mandatory minimum sentences, which are strict prison terms set by law. Thousands of defendants with certain prior convictions will now face longer sentences because they cannot use the 'safety valve' to get a lighter punishment. For example, a person with a single prior serious offense may now be barred from sentencing relief that was previously available in some regions.

The case centers on the First Step Act, a bipartisan law designed to reduce prison overcrowding and fix sentencing disparities. The dispute highlights a common struggle in the legal system: whether to follow the strict grammar of a law or the broader goal Congress had in mind. This decision reinforces a strict reading of the text, even when it results in harsher outcomes for defendants.

Justice Kagan wrote the majority opinion for a 6-3 court, joined by Chief Justice Roberts and Justices Thomas, Alito, Kavanaugh, and Barrett. Justice Gorsuch wrote a dissent joined by Justices Sotomayor and Jackson.

“A defendant must satisfy individually each of the three conditions of the 'safety valve' provision... to be eligible for sentencing relief.”

“The majority elevated unexpressed congressional purposes over the statutory text and dismissed variations in Congress's use of 'and' and 'or' as sloppy mistakes.”

The Supreme Court narrowed the path for drug offenders to get shorter sentences by requiring them to pass all three criminal history tests in the federal safety valve law.

Lower courts across the country must now apply this strict 'checklist' approach to all pending drug sentencing cases. Defense attorneys will likely look for other ways to challenge mandatory minimums, while Congress may consider rewriting the law if they want to clarify their original intent. Observers will watch to see if this leads to a significant increase in the federal prison population.

The parties argued over whether 'and' meant a defendant is disqualified only if they have all three traits, or if having just one is enough to lose relief.

Many nonviolent drug offenders will now receive mandatory minimum sentences instead of shorter, judge-determined terms. This will likely lead to longer stays in federal prison.

The Court used a 'checklist' interpretation, ruling that the context of the law requires defendants to meet every single condition to qualify for a lower sentence.

The case is finished at the Supreme Court level. Lower courts and federal agencies must now follow this ruling when sentencing defendants in similar drug cases.

Yes, it shows the Court's preference for 'textualism,' which means focusing on the specific words of a law rather than what lawmakers might have intended.