United States v. Harden

Flaum, Circuit Judge.

*439A jury convicted defendant-appellant Donald S. Harden of conspiring to distribute heroin, the use of which resulted in the death of Fred Schnettler. Harden was sentenced to life in prison under 21 U.S.C. § 841(b)(1)(B). That provision imposes sentencing enhancements if the defendant commits a drug offense and "death or serious bodily injury results from the use of such substance." On appeal, Harden argues that the prosecution failed to present sufficient evidence to establish beyond a reasonable doubt that his heroin caused Schnettler's death. Relatedly, Harden contends…