Supreme Court of the United States
Bifulco v. United States
June 16, 1980447 U.S. 381
Summary
The Court held that the statute governing attempts and conspiracies to commit controlled-substance offenses does not authorize a special parole term when the target substantive offense carries such a term. The statutory text, structure, legislative history, and policy considerations did not establish an unambiguous congressional intent to impose special parole for conspiracy, so the rule of lenity required resolving the doubt in the defendant's favor. The Court reversed and remanded for vacation of the special parole term.
Holding
- Whether the conspiracy statute authorizes a special parole term by incorporating the target offense's penalty provisions.. The conspiracy statute does not authorize imposition of a special parole term for a conviction of conspiracy to manufacture or distribute a controlled substance, even when the target substantive offense includes special parole among its penalties.
Docket 79-5010
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