United States v. Angel Collado-Gomez and Gustavo Quintero-Gonzalez, Gustavo Quintero-Gonzalez

In 1986, Congress amended 21 U.S.C. § 841(b)(1) (Supp. II 1984) to provide for enhanced penalties for the possession with intent to distribute of specified amounts of certain controlled substances, including a particularly addictive form of cocaine base known as “crack.” See Anti-Drug Abuse Act of 1986, P.L. 99-570, 100 Stat. 3207-4 (codified as amended at 21 U.S.C. § 841(b)(1)). The 1986 amendments did not alter the elements of the substantive offense, which require the government to prove that a defendant knowingly and intentionally possessed a controlled substance. See 21 U.S.C. § 841(a)…