United States v. Rosemary MacDonald Houston

TALLMAN, Circuit Judge:

Rosemary MacDonald Houston was convicted of distributing methadone to Trina Bradford which resulted in Bradford’s death. 21 U.S.C. § 841(a)(1), (b)(1)(C). 1 Houston challenges the sufficiency of the evidence supporting her conviction, and particularly protests being held responsible for a death that she claims was an unforeseeable suicide. We conclude that the plain language of the statute establishes that although cause-in-fact must be proven, foreseeability is not an element of the crime, and that sufficient evidence supports the jury’s verdict as to the remaining…