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Circuit split · criminal sentencing

Whether the statutory term 'cocaine base' is limited to crack cocaine or encompasses all forms of cocaine base

1 federal appellate case on this question, each acknowledging the disagreement in its own words.

  1. First Circuit Court of Appeals · October 25, 2005

    “The question whether the statute regulates only possession of crack or whether its rule encompasses other forms of cocaine base is the subject of some debate and of a conflict among the circuits.” — Split of authority
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The provision at issue

21 U.S.C. § 841 — Prohibited acts A
“(a) Unlawful acts Except as authorized by this subchapter, it shall be unlawful for any person knowingly or intentionally— (1) to manufacture, distribute, or dispense, or possess with intent to manufacture, distribute, or dispense, a controlled substance; or (2) to create, distribute, or dispense, or possess with intent to distribute or dispense, a counterfeit substance. (b) Penalties Except as otherwise provided in section 849, 859, 860, or 861 of this title, any person who violates subsection (a) of this section shall be sentenced as …”
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The other side of the split

Decisions the acknowledging court(s) named as the opposing or joined side, quoted in the acknowledging opinion's own words.

What the split turns on

Cases are grouped by the legal question they announce a split on, classified from the court's own acknowledgment sentence. Verified acknowledgments only. Counter-side decisions are extracted from the acknowledging opinions' own text and linked only when the citation resolves in this corpus. See all circuit splits.