Supreme Court of the United States
Pulsifer v. United States
March 15, 2024601 U.S. 124
Summary
The Court held that the criminal-history provision of the federal sentencing safety valve requires a defendant to satisfy all three listed conditions: having no more than four qualifying criminal-history points, no prior three-point offense, and no prior two-point violent offense. The Court relied on statutory context, the need to give independent effect to each subparagraph, and the provision's function of screening defendants based on the seriousness of their criminal records. Because Pulsifer had two prior three-point offenses totaling six points, he was ineligible for safety-valve relief, and the Court affirmed.
Holding
- Interpretation of the safety-valve criminal-history requirement. Section 3553(f)(1) creates an eligibility checklist with three independently necessary conditions. A defendant is eligible only if he does not have more than four qualifying criminal-history points, does not have a prior three-point offense, and does not have a prior two-point violent offense; the defendant need not possess all three characteristics to be disqualified.
- Rule of lenity. The rule of lenity does not apply because, after considering the text in context, the criminal-history requirement is not genuinely ambiguous.
Docket 22-340
Cited authorities
- CA11
- 10 U. S. C. 801
- 21 U. S. C. 841
- 21 U. S. C. 960
- CA11
- CA11
- 88 FR 7186
- 18 U.S.C. §3553