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Statutes and the Creation of Public Policy Keyed to Eskridge, 7th Ed.
Pulsifer v. United States
Citation:
601 U.S. 124 (2024)Facts
Mark Pulsifer pleaded guilty in 2020 to distributing at least 50 grams of methamphetamine, which subjected him to a mandatory minimum prison sentence of 15 years unless he qualified for the safety valve provision. Pulsifer had two relevant prior convictions in his criminal history, each classified as a three-point offense under the Sentencing Guidelines, giving him a total of six criminal history points. The Government argued that Pulsifer was ineligible for safety-valve relief because he had two prior three-point offenses (violating Subparagraph B) and more than four criminal history points (violating Subparagraph A). Pulsifer countered that he remained eligible because he lacked a prior two-point violent offense as specified in Subparagraph C, and argued that only the combination of all three listed traits would disqualify him from relief. The District Court sided with the Government’s interpretation and denied Pulsifer safety-valve relief, and the Eighth Circuit affirmed this decision.
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