Appeal from the United States District Court
for the Northern District of Ohio at Akron.
No. 5:16-cr-00180-1—Solomon Oliver, Jr., District Judge.
Argued: October 17, 2019
Decided and Filed: May 8, 2020
Before: BOGGS, BATCHELDER, and DONALD, Circuit Judges.
ALICE M. BATCHELDER, Circuit Judge. A jury convicted Jurmaine Jeffries of drugrelated offenses, in violation of 21 U.S.C. § 841(a)(1) and (b)(1)(C). The district court granted
Jeffries’s motion for a new trial, finding that it erroneously failed to include jury instructions that
required the United States to prove proximate causation in addition to but-for causation.
On appeal, the United States argues that § 841(b)(1)(C) requires proof of only but-for causation.
We agree and therefore REVERSE and REMAND for sentencing.