21 U.S.C. § 861
Employment or use of persons under 18 years of age in drug operations
Any person who violates subsection (a) is subject to twice the maximum punishment otherwise authorized and at least twice any term of supervised release otherwise authorized for a first offense. Except to the extent a greater minimum sentence is otherwise provided, a term of imprisonment under this subsection shall not be less than one year.
Any person who violates subsection (a) after a prior conviction under subsection (a) of this section has become final, is subject to three times the maximum punishment otherwise authorized and at least three times any term of supervised release otherwise authorized for a first offense. Except to the extent a greater minimum sentence is otherwise provided, a term of imprisonment under this subsection shall not be less than one year. Penalties for third and subsequent convictions shall be governed by section 841(b)(1)(A) of this title.
In any case of any sentence imposed under this section, imposition or execution of such sentence shall not be suspended and probation shall not be granted. An individual convicted under this section of an offense for which a mandatory minimum term of imprisonment is applicable shall not be eligible for parole under section 4202 of title 18 2
Except as authorized by this subchapter, it shall be unlawful for any person to knowingly or intentionally provide or distribute any controlled substance to a pregnant individual in violation of any provision of this subchapter. Any person who violates this subsection shall be subject to the provisions of subsections (b), (c), and (e).
Section 4202 of title 18, referred to in subsec. (e), which, as originally enacted in Title 18, Crimes and Criminal Procedure, related to eligibility of prisoners for parole, was repealed and a new section 4202 enacted as part of the repeal and enactment of a new chapter 311 (§ 4201 et seq.) of Title 18, by Pub. L. 94–233, § 2,
Section was classified to section 845b of this title prior to renumbering by Pub. L. 101–647.
1990—Subsec. (b). Pub. L. 101–647, § 1003(c)(1), which directed the substitution of “is subject to twice the maximum punishment otherwise authorized” for “is punishable by a term of imprisonment up to twice that authorized, or up to twice the fine authorized, or both,” was executed by making the substitution for “is punishable by a term of imprisonment up to twice that otherwise authorized, or up to twice the fine otherwise authorized, or both,” to reflect the probable intent of Congress.
Subsec. (c). Pub. L. 101–647, § 3599L, substituted “has become final” for “have become final”.
Pub. L. 101–647, § 1003(c)(2), which directed the substitution of “is subject to three times the maximum punishment otherwise authorized” for “is punishable by a term of imprisonment up to three times that authorized, or up to three times the fine authorized, or both,” was executed by making the substitution for “is punishable by a term of imprisonment up to three times that otherwise authorized, or up to three times the fine otherwise authorized, or both,” to reflect the probable intent of Congress.
1988—Subsec. (a)(3). Pub. L. 100–690, § 6459, added par. (3).
Subsec. (c). Pub. L. 100–690, § 6452(b)(1), struck out “or convictions” after “a prior conviction” and inserted at end “Penalties for third and subsequent convictions shall be governed by section 841(b)(1)(A) of this title.”
Subsec. (e). Pub. L. 100–690, § 6470(d), struck out “required by section 841(b) of this title” after “mandatory term of imprisonment”.
Notes of Decisions
Cited in 167
cases (9 in the last 5 years), 1991–2024 · leading case: Rehaif v. United States, 139 S. Ct. 2191 (2019).
Rehaif v. United States, 139 S. Ct. 2191 (2019). “21 U.S.C. § 861 (a)(2). A third applies to a "parent [or] legal guardian" who allows his child to be used for child pornography.”
United States v. Abraham Hernandez, 330 F.3d 964 (7th Cir. 2003). “Counts 2 and 3 charged five of the defendants with using minors in a drug operation in violation of 21 U.S.C. § 861 . The remaining counts charged various individuals with substantive distribution offenses in viola *968 tion of 21 U.”
United States v. Bryan Burwell, 690 F.3d 500 (D.C. Cir. 2012). “§ 2423 (the Mann Act) (prohibiting transportation of juveniles across state lines for the purpose of prostitution); 21 U.S.C. § 861 (criminalizing use of a juvenile to commit or conceal a drug offense)—do not require proof of mens rea with respect to the juvenile’s age.”
United States v. Villanueva-Sotelo, 515 F.3d 1234 (D.C. Cir. 2008). “" 21 U.S.C. § 861 (a)(2). Again observing that the statute was "not a model of meticulous drafting," we explained that "[ o ] ne cannot tell from the words alone whether the person's juvenile status must be known .”
United States v. Llama Edmidia Alarcon Sergio Alarcon-Lopez & Ruben Alarcon-Pinon, 261 F.3d 416 (5th Cir. 2001). “§ 841 (a)(1) (“count two”); and a count of using a minor to avoid detection of or apprehension for an offense in violation of 21 U.S.C. § 861 (a)(2) (“count three”). The Appellants pled not guilty to *420 all three counts, and the trial court set the case for a jury trial.”
United States v. Samuel O. White, Luis Noel Cruz, AKA Danny Cruz, 240 F.3d 127 (2d Cir. 2001). “§ 860 (a) 3 (the “schoolyard counts”); and one count of use of a person under 18 to assist in the distribution of cocaine base and cocaine, in violation of 21 U.S.C. §§ 861 (a)(1) 4 and 861(a)(2) 5 .”
State v. Flores, 164 Wash. 2d 1 (Wash. 2008). “Similar to Washington’s law, 21 U.S.C. § 861 (a)(1) and (2) makes it unlawful for any adult to “employ, hire, use, persuade, induce, entice, or coerce” a minor either to participate in a drug offense or “to assist in avoiding detection or apprehension” for a drug offense.”
State v. Flores, 186 P.3d 1038 (Wash. 2008). “Similar to Washington's law, 21 U.S.C. § 861 (a)(1), (2) makes it unlawful for any adult to "employ, hire, use, persuade, induce, entice, or coerce" a minor to either participate in a drug offense or "to assist in avoiding detection or apprehension" for a drug offense.”
Flores-Figueroa v. United States, 556 U.S. 646 (2009). “employ, hire, use, persuade, induce, entice, or coerce, a person under eighteen years of age to violate” drug laws, does not require the defendant to have knowledge of the Cite as: 556 U. S. ____ (2009) 3 Opinion of ALITO, J.”
United States v. Polizzi, 549 F. Supp. 2d 308 (E.D.N.Y 2008). “§ 860 (b) Third offense; distribution of a controlled substance near’ a school or similar facility Mandatory minimum term of imprisonment specified at section 841(b)(1)(A) 21 U.S.C. § 861 (a) Employment or use of persons under 18 years of age in drug operations Mandatory minimum…”
United States v. Louis Zayas, 32 F.4th 211 (3rd Cir. 2022). “3 controlled substance to a pregnant individual in violation of 21 U.S.C. §§ 861 (f), 841(a)(1) and (b)(1)(C), and 18 U.”
United States v. Harris, 258 F. Supp. 3d 137 (D.D.C. 2017). “§ 845b, recodified at 21 U.S.C. § 861 . 4 Violation of this statute triggers imposition of a term of supervised release of “at least twice the term of supervised release otherwise authorized for a first offense.”
United States v. Frank Smith, Keith McCain Russell Ellis, Eric Wilson, Sherman Moore, Steven Pink & Charles Poteete, 223 F.3d 554 (7th Cir. 2000). “Counts 3, 4: Using minors to further drug conspiracy and to avoid detection, 21 U.S.C. § 861 (a), 18 U.S.C. § 2 . Counts 5-8, 10, 11, 13-17, 28, 38, 39: Possession and distribution of drugs by various individuals, 21 U.”
United States v. Bobby Carrol Cook, United States of Am. v. Bobby Carrol Cook, 76 F.3d 596 (4th Cir. 1996). “Cook’s primary contention is that the district court erred in failing to instruct the jury that it was required to find that he knew that the person from whom he received drugs was a minor in order to convict him of violating 21 U.S.C. § 861 (a)(3). Because § 861(a)(3) does not…”
United States v. Nazareth Wilson, 237 F.3d 827 (7th Cir. 2001). “For all this, he received a sentence of 420 months, to be followed by 10 years of supervised release.”
United States v. Puig-Infante, 19 F.3d 929 (5th Cir. 1994). “§ 2 and 21 U.S.C. § 861 (a)(1). The case was tried before a jury in the United States District Court for the Southern District of Texas, and on April 2, 1992, the jury returned a guilty verdict on all counts against all appellants except Perla De Los Santos.”
United States v. Andrew P. Chin, 981 F.2d 1275 (D.C. Cir. 1992). “§ 845b(a), recodified at 21 U.S.C. § 861 (a). This phrasing is not a model of meticulous drafting.”
United States v. Matthew Jones, 960 F.3d 949 (7th Cir. 2020). “3d at 571–72, discussing 21 U.S.C. § 861 (a). Maez’s indictment did not contain a plain error.”
United States v. Ramirez, 708 F.3d 295 (1st Cir. 2013). “Ramírez further objected to any sentence enhancement under 21 U.S.C. § 861 (b) for use of a person under 18 since he did not admit at the change-of-plea hearing that he knew BR was a minor.”
United States v. Charles E. Jones, Iii, A/K/A Chuckie, 471 F.3d 535 (4th Cir. 2006). “With regard to a similar statute, this court has held that conviction under 21 U.S.C. § 861 (a)(3) for receiving a controlled substance from a person under 18 years of age does not require proof that the defendant knew the other party was underage.”
United States v. Marciano Vasquez, 899 F.3d 363 (5th Cir. 2018). “Count five charged the employment of minors in drug operations, in violation of 21 U.S.C. § 861 (a)(1) and 18 U.S.C. § 2 .”
Rehaif v. United States, 588 U.S. 225 (2019). “21 U. S. C. §861 (a)(2). A third applies to a “parent [or] legal guardian” who al- lows his child to be used for child pornography.”
United States v. Lombardi, 138 F.3d 559 (5th Cir. 1998). “§ 2 , aiding and abetting possession with the intent to distribute; (3) violating 21 U.S.C. § 861 (a)(1), (2), knowingly and intentionally employing, hiring, using, persuading, inducing, enticing, or coercing a juvenile to commit a drug offense or to assist in avoiding detection…”
United States v. Benjamin, 391 F. App'x 942 (2d Cir. 2010). “Donald Benjamin’s Sentence on Count 24 Donald Benjamin was convicted on Count 24 of violating of 21 U.S.C. § 861 . That section makes it a crime, among other things, to “use” a “person under eighteen years of age to violate any provision of’ Title 21 of the United States Code.”
United States v. Pineda-Doval, 614 F.3d 1019 (9th Cir. 2010). “§ 859b, now codified at 21 U.S.C. § 861 ). A 10-year minimum sentence applies if a firearm is discharged during the commission of a drug trafficking crime.”
United States v. William G. Curtis & Jamell L. Rouson, 324 F.3d 501 (7th Cir. 2003). “§ 846 ; employment of a minor in the distribution of crack cocaine in violation of 21 U.S.C. § 861 (a)(1); two counts of the use of a firearm to commit murder in furtherance of a drug conspiracy for two separate killings in violation of 18 U.”
United States v. Kenneth James, 928 F.3d 247 (3rd Cir. 2019). “See 21 U.S.C. § 861 (a) (making it unlawful only "for any person at least eighteen years of age to knowingly and intentionally - - employ .”
United States v. Lynard Joiner & James E. Collins, Also Known as Duke, 183 F.3d 635 (7th Cir. 1999). “§ 841 (a)(1), and employment of a juvenile in a drug offense, in violation of 21 U.S.C. § 861 (a)(1). After Joiner and Collins entered into separate, negotiated plea agreements, they were sentenced to 235 months’ and 360 months’ imprisonment, respectively.”
United States v. Brewer, 199 F.3d 1283 (11th Cir. 2000). “§ 841 (a)(1) (Counts 5 and 6), on one count of employment of a minor to distribute cocaine base, in violation of 21 U.S.C. § 861 (a) (Count 8), and on one count of use of a firearm during and in relation to a drug trafficking crime, in violation of 18 U.”
United States v. Dunbar, 553 F.3d 48 (1st Cir. 2009). “21 U.S.C. § 861 (a)(1). We agree. Considering the history of Dunbar and Spaulding, there is little doubt that Dunbar’s assault of Spaulding with a broom provides evidence probative of the fact that Dunbar coerced Spaulding to follow his instructions in implementing acts in…”
United States v. Stephen Golden, 102 F.3d 936 (7th Cir. 1996). “§ 924 (c), and employment of juveniles for drug distribution in violation of 21 U.S.C. § 861 (a)(1). On appeal, Golden argues that the district court should have granted his mid-trial request for new counsel, that there was insufficient evidence for the district court to…”
United States v. Molina, 469 F.3d 408 (5th Cir. 2006). “We recognize that Alarcon is not controlling because the panel in that case was considering whether there was sufficient evidence to support a conviction for the use of a minor in avoiding detection of an offense, in violation of 21 U.S.C. § 861 (a)(2). See Alarcon, 261 *416 F.”
United States v. Cox, 577 F.3d 833 (7th Cir. 2009). “For example, we have held that the Government need not prove that the defendant knew her victim was a minor in order to obtain a conviction under 21 U.S.C. § 861 (a)(1). United States v. Frazier, 213 F.”
United States v. Mata, 624 F.3d 170 (5th Cir. 2010). “Alarcon reviewed the sufficiency of the evidence in support of a conviction for the use of a minor in avoiding detection in violation of 21 U.S.C. § 861 (a)(2), id., but we have previously found Alarcon to be “instructive as to what conduct constitutes use of a minor” under §…”
United States v. Prather, 205 F.3d 1265 (11th Cir. 2000). “BARRETT, Circuit Judge: Vernon Victor Prather appeals his conviction for conspiracy to distribute pseu-doephedrine in violation of 21 U.S.C. §§ 861 (d)(2) and 846, distribution of pseu-doephedrine in violation of 21 U.”
United States v. Garcia, 27 F.3d 1009 (5th Cir. 1994). “They assert that count one charged only a conspiracy to violate 21 U.S.C. § 861 (a)(2), which proscribes use of a minor to avoid detection or apprehension of an offense.”
United States v. Charles Morgan, Jr., 45 F.4th 192 (D.C. Cir. 2022). “That case involved 21 U.S.C. § 861 (a), which makes it a crime to “knowingly and intentionally .”
United States v. Thomas L. Hudspeth, 42 F.3d 1015 (7th Cir. 1994). “§ 860 ); and (5) involving a person under 18 years of age in a drug transaction ( 21 U.S.C. § 861 ). . The police reports do not establish with any certainty the sequence of the burglaries or the precise means of entry.”
United States v. Gregory M. Thomas, 114 F.3d 228 (D.C. Cir. 1997). “§§ 845 (b), (a)(1) (1984) (now 21 U.S.C. § 861 (1996)), 841(a)(1) & 841(b)(l)(A)(iv) & (b)(1)(D) (Count 11).”
United States v. Corchado, 427 F.3d 815 (10th Cir. 2005). “§ 841 (a)(1) and one count of using a minor to commit a drug offense in violation of 21 U.S.C §§ 861(a)(1) and (b). *817 The district court sentenced Defendant to eighty-seven months imprisonment.”
United States v. Nicolas Manueles Montejo, 442 F.3d 213 (4th Cir. 2006).
United States v. William Beverly William Pritchett, Also Known as O & Reginald Brown, Charles Tyrone White, Also Known as Nfn Black, & Dana Foster, 5 F.3d 633 (2d Cir. 1993).
United States v. Pablo Salinas Brito Adrian Brito Jesus Salinas Brito Adan Brito Ignacio Berumez Brito Benjamin Hernandez Rodriguez, 136 F.3d 397 (5th Cir. 1998).
United States v. Marcus Morgan, Also Known as Red Ryan Jackson, Also Known as Anthony, Also Known as Tony Jarvis Wright, Also Known as Jaye, 117 F.3d 849 (5th Cir. 1997).
United States v. Courtney Butler (98-5552) & Julius Retic (98-5554), 207 F.3d 839 (6th Cir. 2000).
United States v. Perry A. Graham, United States of Am. v. Terrence A. Terrell, United States of Am. v. Roger v. Smith, 83 F.3d 1466 (D.C. Cir. 1996).
United States v. Artez Lamont Rogers & Harrison R. King, 89 F.3d 1326 (7th Cir. 1996).
United States v. Eric L. Frazier, Jacoby Walker & Michael Mason, 213 F.3d 409 (7th Cir. 2000).
United States v. Derrick Jarrett, Lawrence McCarroll Jeffrey Brock, Jamie J. Key, Dwight Anderson, Samir Hameen, & Judy McCarroll, 133 F.3d 519 (7th Cir. 1998).
United States v. Isaac, 655 F.3d 148 (3rd Cir. 2011).
United States v. Ramírez, 708 F.3d 295 (1st Cir. 2013).
United States v. Cyprian, 197 F.3d 736 (5th Cir. 1999).
United States v. Sean Meacham (93-1692) & Ramone Botello (93-1768), 27 F.3d 214 (6th Cir. 1994).
United States v. Todd Michael Porter, 986 F.2d 1014 (6th Cir. 1993).
United States v. James Brown, A/K/A Steven Brown, 16 F.3d 423 (D.C. Cir. 1994).
United States v. Orestes Luciano Abreu, United States of Am. v. James David Thornbrugh, 962 F.2d 1447 (10th Cir. 1992).
United States of Am., Appellee-Cross-Appellant v. Benjamin Gary Triestman, Defendant-Appellant-Cross-Appellee, 178 F.3d 624 (2d Cir. 1999).
DeFeo v. United States, 153 F. Supp. 2d 453 (S.D.N.Y. 2001).
United States v. David Fields, 39 F.3d 439 (3rd Cir. 1994).
Benjamin v. United States, 154 F. Supp. 3d 1 (W.D.N.Y. 2016).
United States v. Cargill, 17 F. App'x 214 (4th Cir. 2001).
United States v. Mitchell Locklear, United States of Am. v. Lee Allen Lowry, 24 F.3d 641 (4th Cir. 1994).
United States v. Armando Vera, 893 F.3d 689 (9th Cir. 2018).
United States v. McCray, 7 F.4th 40 (2d Cir. 2021).
WildEarth Guardians v. U.S. Dep't of Just., 283 F. Supp. 3d 783 (D. Ariz. 2017).
United States v. Jackson, 199 F. Supp. 2d 1081 (D. Kan. 2002).
United States v. Figueroa, 165 F.3d 111 (2d Cir. 1998).
United States v. Hirliman, 503 F.3d 212 (2d Cir. 2007).
United States v. James Alfred Miller, 91 F.3d 1160 (8th Cir. 1996).
United States v. Raul Martinez-Morel, 118 F.3d 710 (10th Cir. 1997).
United States v. LaShonda Hall, 516 F. App'x 433 (6th Cir. 2013).
United States v. Millard Williams, 106 F.4th 639 (7th Cir. 2024).
United States v. Newton, 44 F.3d 913 (11th Cir. 1994).
United States v. Harris, 959 F.2d 246 (D.C. Cir. 1992).
United States v. Ferris Lavelle Lee, 687 F.3d 935 (8th Cir. 2012).
United States v. Takeshi Brown, 33 F.3d 1014 (8th Cir. 1994).
United States v. Ronald Earl Clay, 117 F.3d 317 (6th Cir. 1997).
United States v. Robert Rae Ramirez, 376 F.3d 785 (8th Cir. 2004).
United States v. Aaron Duane Rees, 447 F.3d 1128 (8th Cir. 2006).
United States v. Keith E. Brazinskas, 458 F.3d 666 (7th Cir. 2006).
United States v. Smith, 574 F.3d 521 (8th Cir. 2009).
United States v. Salazar-Montero, 520 F. Supp. 2d 1079 (N.D. Iowa 2007).
UNITED STATES of Am., Plaintiff-Appellee, v. Mariano Serratos BELTRAN, Defendant-Appellant, 165 F.3d 1266 (9th Cir. 1999).
United States v. Hernandez-Bautista, 293 F.3d 845 (5th Cir. 2002).
United States v. Melvin L. Lampkin, 159 F.3d 607 (D.C. Cir. 1999).
United States v. Jones, 965 F.2d 1507 (8th Cir. 1992).
United States v. Rhines, 143 F. App'x 478 (3rd Cir. 2005).
United States v. Wilson, 11 F.3d 346 (2d Cir. 1993).
United States v. Mark Steven Ayala, 313 F.3d 1068 (8th Cir. 2002).
United States v. Keyes, 214 F. App'x 145 (3rd Cir. 2007).
United States v. Evans, 82 F. App'x 726 (2d Cir. 2003).
United States v. Morsette, 858 F. Supp. 2d 1049 (D.N.D. 2012).
United States v. Smith, 26 F.3d 739 (7th Cir. 1994).
United States v. Robert B. Fletcher, A/K/A Fletch, United States of Am. v. Darryl Blalock, A/K/A Mookie, 945 F.2d 725 (4th Cir. 1991).
United States v. Rivera Maldonado, 124 F. Supp. 2d 788 (D.P.R. 2000).
United States v. Clay, 39 F. App'x 176 (6th Cir. 2002).
United States v. Holland, 985 F. Supp. 587 (D. Maryland 1997).
United States v. Evans, 352 F.3d 65 (2d Cir. 2003).
United States v. Jackson-Bey, 302 F. Supp. 2d 621 (E.D. Va. 2004).
Little v. United States, 184 F. Supp. 2d 489 (E.D. Va. 2002).
United States v. Dale Anthony Stephens, 35 F.3d 451 (9th Cir. 1994).
State v. Hollis, 970 P.2d 813 (Wash. Ct. App. 1999).
United States v. Palmer, Michael, 296 F.3d 1135 (D.C. Cir. 2002).
United States v. Birbragher, 576 F. Supp. 2d 1000 (N.D. Iowa 2008).
United States v. Ronald Eugene McClain, 252 F.3d 1279 (11th Cir. 2001).
Golden v. United States, 35 F. Supp. 2d 664 (N.D. Ind. 1999).
Parker v. United States, 745 A.2d 933 (D.C. 2000).
United States v. Pannell, 28 F. App'x 696 (9th Cir. 2002).
United States v. Calvin Delpit, 94 F.3d 1134 (8th Cir. 1996).
United States v. Alarcon (5th Cir. 2001).
United States v. Hernandez, Abraham (7th Cir. 2003).
United States v. Harbin, Driefus, 250 F.3d 532 (7th Cir. 2001).
United States v. Quintanilla, Miguel, 302 F.3d 679 (7th Cir. 2002).
United States v. Durrell Jackson, 345 F.3d 638 (8th Cir. 2003).
United States v. Harriot, 37 F. App'x 601 (4th Cir. 2002).
United States v. Kenneth Shaw, 94 F.3d 438 (8th Cir. 1996).
United States v. Fernando Davis, 154 F.3d 772 (8th Cir. 1998).
Rehaif v. United States (2019).
United States v. Gayle (2d Cir. 2019).
Clark v. United States (W.D.N.C. 2020).
DeVaughn v. United States (N.D.W. Va. 2022).
United States v. Bullock (4th Cir. 2000).
United States v. Herbert DeVaughn, 526 F. App'x 319 (4th Cir. 2013).
United States v. Thompson, 232 F. App'x 343 (4th Cir. 2007).
United States v. Jones (4th Cir. 2006).
United States v. Jackson, 94 F. Supp. 2d 935 (N.D. Ill. 2000).
United States v. Marciano Vasquez (5th Cir. 2018).
United States v. Charles Stansbury (3rd Cir. 2019).
United States v. Matthew Jones (7th Cir. 2020).
United States v. Kyle Michael Brewer (11th Cir. 2020).
United States v. Smith (D.D.C. 2021).
United States v. Tymir Wigfall (4th Cir. 2022).
United States v. Tymir Wigfall (4th Cir. 2022).
United States v. Wyche (D.D.C. 2023).
Cuellar, Jr. v. Quay (M.D. Penn. 2019).
United States v. Orona-Castillo, 156 F. App'x 683 (5th Cir. 2005).
United States v. Mata, 624 F.3d 170 (5th Cir. 2010).
United States v. Samuel Myles, 498 F. App'x 665 (8th Cir. 2013).
United States v. Compton Jones, 502 F. App'x 600 (7th Cir. 2013).
United States v. Washington, 36 F. App'x 738 (4th Cir. 2002).
United States v. Kyle Michael Brewer, 536 F. App'x 923 (11th Cir. 2013).
Haywood v. United States, 216 F. Supp. 2d 725 (N.D. Ill. 2002).
United States v. Hernandez-Bautista, 159 F. Supp. 2d 410 (W.D. Tex. 2001).
Rosario v. United States, 380 F. Supp. 2d 983 (N.D. Ill. 2005).
United States v. Stevenson, 135 F. Supp. 2d 878 (N.D. Ill. 2001).
United States v. Benjamin (2d Cir. 2007).
United States v. Montejo (4th Cir. 2006).
United States v. Akers, 135 F. App'x 856 (6th Cir. 2005).
United States v. Curtis, William G. (7th Cir. 2003).
United States v. Brazinskas, Keith (7th Cir. 2006).
United States v. Tommy Cox (7th Cir. 2009).
United States v. Mark Steven Ayala (8th Cir. 2002).
United States v. Leonardo Burgos-Valencia (9th Cir. 2010).
United States v. Robert Ramirez (8th Cir. 2004).
United States v. Aaron Duane Rees (8th Cir. 2006).
United States v. Gene Smith (8th Cir. 2009).
United States v. Mark Ayala, 351 F. App'x 147 (8th Cir. 2009).
United States v. Encinas-Martinez, 358 F. App'x 954 (9th Cir. 2009).
United States v. Encinas-Martinez, 358 F. App'x 954 (9th Cir. 2009).
United States v. Olson, 241 F. App'x 369 (9th Cir. 2007).
United States v. Brewer, 199 F.3d 1283 (11th Cir. 2000).
United States v. Prather, 205 F.3d 1265 (11th Cir. 2000).
United States v. Martinez-Morel (10th Cir. 1997).
United States v. Jaramillo-Garcia (10th Cir. 2000).
United States v. Walker (4th Cir. 1998).
United States v. Retic (6th Cir. 2000).
United States v. James Alfred Miller (8th Cir. 1996).
— 21 U.S.C. § 861(a)(1) — 1 case
United States v. Corchado, 427 F.3d 815 (10th Cir. 2005). “§ 841 (a)(1) and one count of using a minor to commit a drug offense in violation of 21 U.S.C §§ 861(a)(1) and (b). *817 The district court sentenced Defendant to eighty-seven months imprisonment.”
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