Pulsifer v. United States

Mark Pulsifer pleaded guilty to distributing methamphetamine, facing a mandatory minimum sentence of 15 years. He sought relief under the First Step Act's safety valve provision, which allows courts to disregard mandatory minimums for certain nonviolent drug offenders. The dispute centered on whether a defendant must satisfy all three criminal history conditions listed in 18 U.S.C. § 3553(f)(1) to be eligible. Lower courts split over whether the word and meant a defendant was disqualified only by meeting all three conditions, or disqualified by meeting any single condition. The Eighth Circuit held that Pulsifer was ineligible because he met two of the three conditions. The Supreme Court granted certiorari to resolve the circuit split and interpret the conjunctive phrasing.

In a 6-3 opinion authored by Justice Kagan, the Supreme Court reversed the Eighth Circuit. It held that the plain text of the statute demands a conjunctive reading: a defendant is disqualified from safety valve relief only if they meet all three criminal history conditions. Because Pulsifer satisfied only two, he remains eligible for a sentence below the mandatory minimum. The case was remanded for resentencing consistent with the opinion. Justice Gorsuch filed a dissenting opinion joined by Justices Sotomayor and Jackson.

The central dispute was the interpretation of the word "and" in the safety valve provision’s criminal history requirements: whether the three subparagraphs (A), (B), and (C) operate conjunctively, so a defendant is ineligible only if they have all three, or disjunctively, so having any one of them bars relief.

The ruling significantly broadens the pool of federal defendants eligible to bypass harsh mandatory minimum sentences. By clarifying that the safety valve requires meeting all three criminal history triggers for disqualification, the decision reduces incarceration for thousands of nonviolent drug offenders and eases federal prison overcrowding. It also resolves deep circuit splits, providing uniformity in federal sentencing courts nationwide and reinforcing textualist approaches to statutory interpretation at the Supreme Court.