OCTOBER TERM, 1995
Syllabus
UNITED STATES
v. ARMSTRONG ET AL.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH
CIRCUIT
No. 95-157. Argued February 26, 1996-Decided May 13, 1996
In response to their indictment on "crack" cocaine and other
federal charges, respondents filed a motion for discovery or for
dismissal, alleging that they were selected for prosecution because
they are black. The District Court granted the motion over the
Government's argument, among others, that there was no evidence or
allegation that it had failed to prosecute nonblack defendants.
When the Government indicated it would not comply with the
discovery order, the court dismissed the case. The en banc Ninth
Circuit affirmed, holding that the proof requirements for a
selective-prosecution claim do not compel a defendant to
demonstrate that the Government has failed to prosecute others who
are similarly situated.
Held: For a defendant to be entitled to discovery on a
claim that he was singled out for prosecution on the basis of his
race, he must make a threshold showing that the Government declined
to prosecute similarly situated suspects of other races.
Pp.461-471.
(a) Contrary to respondents' contention, Federal Rule of
Criminal Procedure 16, which governs discovery in criminal cases,
does not support the result reached by the Ninth Circuit in this
case. Rule 16(a)(I)(C)-which,
inter alia, requires the
Government to permit discovery of documents that are "material to
the preparation of the ... defense" or "intended for use by the
government as evidence in chief"applies only to the preparation of
the "defense" against the Government's case in chief, not to the
preparation of selective-prosecution claims. This reading creates a
perceptible symmetry between the types of documents referred to in
the Rule. Moreover, its correctness is established beyond
peradventure by Rule 16(a)(2), which, as relevant here, exempts
from discovery the work product of Government attorneys and agents
made in connection with the case's investigation. Respondents'
construction of "defense" as including selective-prosecution claims
is implausible: It creates the anomaly of a defendant's being able
to examine all Government work product under Rule 16(a)(I)(C),
except that which is most pertinent, the work product in connection
with his own case, under Rule 16(a)(2). Pp. 461-463.
(b) Under the equal protection component of the Fifth
Amendment's Due Process Clause, the decision whether to prosecute
may not be based
457
on an arbitrary classification such as race or religion.
Oyler v.
Boles, 368 U. S. 448, 456. In
order to prove a selective-prosecution claim, the claimant must
demonstrate that the prosecutorial policy had a discriminatory
effect and was motivated by a discriminatory purpose.
Ibid.
To establish a discriminatory effect in a race case, the claimant
must show that similarly situated individuals of a different race
were not prosecuted.
Ah Sin v.
Wittman, 198 U. S. 500.
Batson v.
Kentucky, 476 U. S. 79, and
Hunter v.
Underwood, 471 U. S. 222,
distinguished. Although
Ah Sin involved federal review of a
state conviction, a similar rule applies where the power of a
federal court is invoked to challenge an exercise of one of the
core powers of the Executive Branch of the Federal Government, the
power to prosecute. Discovery imposes many of the costs present
when the Government must respond to a prima facie case of selective
prosecution. Assuming that discovery is available on an appropriate
showing in aid of a selective-prosecution claim, see
Wade v.
United States, 504 U. S. 181, the
justifications for a rigorous standard of proof for the elements of
such a case thus require a correspondingly rigorous standard for
discovery in aid of it. Thus, in order to establish entitlement to
such discovery, a defendant must produce credible evidence that
similarly situated defendants of other races could have been
prosecuted, but were not. In this case, respondents have not met
this required threshold. Pp. 463-471.
48 F.3d
1508, reversed and remanded.
REHNQUIST, C. J., delivered the opinion of the Court, in which
O'CONNOR, SCALIA, KENNEDY, SOUTER, THOMAS, and GINSBURG, JJ.,
joined, and in which BREYER, J., joined in part. SOUTER, J.,
post, p. 471, and GINSBURG, J.,
post, p. 471, filed
concurring opinions. BREYER, J., filed an opinion concurring in
part and concurring in the judgment,
post, p. 471. STEVENS,
J., filed a dissenting opinion,
post, p. 476.
Solicitor General Days argued the cause for the United States.
With him on the briefs were Acting Assistant Attorney General
Keeney, Deputy Solicitor General Dreeben, Irving L. Gornstein, and
Kathleen A. Felton.
Barbara E. O'Connor, by appointment of the Court, 516 U.
S. 1007, argued the cause for respondents. With her on the brief
for respondents Martin et al. were
Maria E. Stratton,
Timothy C.
Lannen, by appointment of the Court, 516 U.
S. 1007,
David Dudley, Bernard J. Rosen,
and
458
Eric Schnapper. Joseph F. Walsh, by appointment of the
Court, 516 U. S. 1007, filed a brief for respondent Rozelle. *
CHIEF JUSTICE REHNQUIST delivered the opinion of the Court.
In this case, we consider the showing necessary for a defendant
to be entitled to discovery on a claim that the prosecuting
attorney singled him out for prosecution on the basis of his race.
We conclude that respondents failed to satisfy the threshold
showing: They failed to show that the Government declined to
prosecute similarly situated suspects of other races.
In April 1992, respondents were indicted in the United States
District Court for the Central District of California on charges of
conspiring to possess with intent to distribute more than 50 grams
of cocaine base (crack) and conspiring to distribute the same, in
violation of 21 U. S. C. §§ 841 and 846 (1988 ed. and Supp. IV),
and federal firearms offenses. For three months prior to the
indictment, agents of the Federal Bureau of Alcohol, Tobacco, and
Firearms and the Narcotics Division of the Inglewood, California,
Police Department had infiltrated a suspected crack distribution
ring by using three confidential informants. On seven separate
occasions during this period, the informants had bought a total of
124.3 grams of crack from respondents and witnessed respondents
carrying firearms during the sales. The agents searched the hotel
room in which the sales were transacted, arrested respondents
Armstrong and Hampton in the room, and found
*Briefs of
amici curiae urging reversal were filed for
the Criminal Justice Legal Foundation by
Kent F.
Scheidegger; and for the Washington Legal Foundation et al.
by
Daniel J. Popeo and
Richard A.
Samp.
Briefs of
amici curiae urging affirmance were filed for
former law enforcement officials and police organizations et al. by
David Cole; for the National Association of Criminal Defense
Lawyers by
Judy Clarke and
Nancy Hollander; and for
the NAACP Legal Defense and Educational Fund, Inc., et al. by
Elaine R. Jones, Theodore M. Shaw, George H. Kendall, and
Steven R. Shapiro.
459
more crack and a loaded gun. The agents later arrested the other
respondents as part of the ring.
In response to the indictment, respondents filed a motion for
discovery or for dismissal of the indictment, alleging that they
were selected for federal prosecution because they are black. In
support of their motion, they offered only an affidavit by a
"Paralegal Specialist," employed by the Office of the Federal
Public Defender representing one of the respondents. The only
allegation in the affidavit was that, in every one of the 24 § 841
or § 846 cases closed by the office during 1991, the defendant was
black. Accompanying the affidavit was a "study" listing the 24
defendants, their race, whether they were prosecuted for dealing
cocaine as well as crack, and the status of each case.1
The Government opposed the discovery motion, arguing, among
other things, that there was no evidence or allegation "that the
Government has acted unfairly or has prosecuted non-black
defendants or failed to prosecute them." App. 150. The District
Court granted the motion. It ordered the Government (1) to provide
a list of all cases from the last three years in which the
Government charged both cocaine and firearms offenses, (2) to
identify the race of the defendants in those cases, (3) to identify
what levels of law enforcement were involved in the investigations
of those cases, and (4) to explain its criteria for deciding to
prosecute those defendants for federal cocaine offenses.
Id., at 161-162.
The Government moved for reconsideration of the District Court's
discovery order. With this motion it submitted af-
1 Other defendants had introduced this study in support of
similar discovery motions in at least two other Central District
cocaine prosecutions. App. 83. Both motions were denied. One
District Judge explained from the bench that the 23-person sample
before him was "statistically insignificant," and that the evidence
did not indicate "whether there is a bias in the distribution of
crime that says black people use crack cocaine, hispanic people use
powdered cocaine, caucasian people use whatever it is they use."
Id., at 119, 120.
460
fidavits and other evidence to explain why it had chosen to
prosecute respondents and why respondents' study did not support
the inference that the Government was singling out blacks for
cocaine prosecution. The federal and local agents participating in
the case alleged in affidavits that race played no role in their
investigation. An Assistant United States Attorney explained in an
affidavit that the decision to prosecute met the general criteria
for prosecution, because
"there was over 100 grams of cocaine base involved, over twice
the threshold necessary for a ten year mandatory minimum sentence;
there were multiple sales involving multiple defendants, thereby
indicating a fairly substantial crack cocaine ring; ... there were
multiple federal firearms violations intertwined with the narcotics
trafficking; the overall evidence in the case was extremely strong,
including audio and videotapes of defendants; ... and several of
the defendants had criminal histories including narcotics and
firearms violations." Id., at 81.
The Government also submitted sections of a published 1989 Drug
Enforcement Administration report which concluded that
"[l]arge-scale, interstate trafficking networks controlled by
Jamaicans, Haitians and Black street gangs dominate the manufacture
and distribution of crack." J. Featherly & E. Hill, Crack
Cocaine Overview 1989; App. 103.
In response, one of respondents' attorneys submitted an
affidavit alleging that an intake coordinator at a drug treatment
center had told her that there are "an equal number of caucasian
users and dealers to minority users and dealers."
Id., at
138. Respondents also submitted an affidavit from a criminal
defense attorney alleging that in his experience many nonblacks are
prosecuted in state court for crack offenses,
id., at 141,
and a newspaper article reporting that federal "crack criminals ...
are being punished far more severely than if they had been caught
with powder cocaine,
461
and almost every single one of them is black," Newton, Harsher
Crack Sentences Criticized as Racial Inequity, Los Angeles Times,
Nov. 23, 1992, p. 1; App. 208-210.
The District Court denied the motion for reconsideration.
When the Government indicated it would not comply with the
court's discovery order, the court dismissed the case.2
A divided three-judge panel of the Court of Appeals for the
Ninth Circuit reversed, holding that, because of the proof
requirements for a selective-prosecution claim, defendants must
"provide a colorable basis for believing that 'others similarly
situated have not been prosecuted'" to obtain discovery.
21 F.3d
1431, 1436 (1994) (quoting
United States v.
Wayte, 710 F.2d
1385, 1387 (CA9 1983), aff'd,
470 U. S. 598 (1985)).
The Court of Appeals voted to rehear the case en bane, and the en
bane panel affirmed the District Court's order of dismissal,
holding that "a defendant is not required to demonstrate that the
government has failed to prosecute others who are similarly
situated."
48 F.3d
1508, 1516 (1995) (emphasis deleted). We granted certiorari to
determine the appropriate standard for discovery for a
selectiveprosecution claim. 516 U. S. 942 (1995).
Neither the District Court nor the Court of Appeals mentioned
Federal Rule of Criminal Procedure 16, which by its terms governs
discovery in criminal cases. Both parties now discuss the Rule in
their briefs, and respondents contend that it supports the result
reached by the Court of Appeals. Rule 16 provides, in pertinent
part:
"Upon request of the defendant the government shall permit the
defendant to inspect and copy or photograph books, papers,
documents, photographs, tangible objects,
2We have never determined whether dismissal of the indictment,
or some other sanction, is the proper remedy if a court determines
that a defendant has been the victim of prosecution on the basis of
his race. Here, "it was the government itself that suggested
dismissal of the indictments to the district court so that an
appeal might lie."
48 F.3d
1508,
1510 (CA9 1995).
462
buildings or places, or copies or portions thereof, which are
within the possession, custody or control of the government, and
which are material to the preparation of the defendant's defense or
are intended for use by the government as evidence in chief at the
trial, or were obtained from or belong to the defendant." Fed. Rule
Crim. Proc. 16(a)(1)(C).
Respondents argue that documents "within the possession ... of
the government" that discuss the Government's prosecution strategy
for cocaine cases are "material" to respondents'
selective-prosecution claim. Respondents argue that the Rule
applies because any claim that "results in nonconviction" if
successful is a "defense" for the Rule's purposes, and a successful
selective-prosecution claim has that effect. Tr. of Oral Arg.
30.
We reject this argument, because we conclude that in the context
of Rule 16 "the defendant's defense" means the defendant's response
to the Government's case in chief. While it might be argued that as
a general matter, the concept of a "defense" includes any claim
that is a "sword," challenging the prosecution's conduct of the
case, the term may encompass only the narrower class of "shield"
claims, which refute the Government's arguments that the defendant
committed the crime charged. Rule 16(a)(1)(C) tends to support the
"shield-only" reading. If "defense" means an argument in response
to the prosecution's case in chief, there is a perceptible symmetry
between documents "material to the preparation of the defendant's
defense," and, in the very next phrase, documents "intended for use
by the government as evidence in chief at the trial."
If this symmetry were not persuasive enough, subdivision (a)(2)
of Rule 16 establishes beyond peradventure that "defense" in
subdivision (a)(l)(C) can refer only to defenses in response to the
Government's case in chief. Rule 16(a)(2), as relevant here,
exempts from defense inspection "reports, memoranda, or other
internal government documents made
463
by the attorney for the government or other government agents in
connection with the investigation or prosecution of the case."
Under Rule 16(a)(1)(C), a defendant may examine documents
material to his defense, but, under Rule 16(a)(2), he may not
examine Government work product in connection with his case. If a
selective-prosecution claim is a "defense," Rule 16(a)(1)(C) gives
the defendant the right to examine Government work product in every
prosecution except his own. Because respondents' construction of
"defense" creates the anomaly of a defendant's being able to
examine all Government work product except the most pertinent, we
find their construction implausible. We hold that Rule 16(a)(1)(C)
authorizes defendants to examine Government documents material to
the preparation of their defense against the Government's case in
chief, but not to the preparation of selective-prosecution
claims.
In
Wade v.
United States, 504 U. S. 181 (1992), we
considered whether a federal court may review a Government decision
not to file a motion to reduce a defendant's sentence for
substantial assistance to the prosecution, to determine whether the
Government based its decision on the defendant's race or religion.
In holding that such a decision was reviewable, we assumed that
discovery would be available if the defendant could make the
appropriate threshold showing, although we concluded that the
defendant in that case did not make such a showing. See
id.,
at 186. We proceed on a like assumption here.
A selective-prosecution claim is not a defense on the merits to
the criminal charge itself, but an independent assertion that the
prosecutor has brought the charge for reasons forbidden by the
Constitution. Our cases delineating the necessary elements to prove
a claim of selective prosecution have taken great pains to explain
that the standard is a demanding one. These cases afford a
"background presumption," cf.
United States v.
Mezzanatto, 513 U. S. 196, 203
464
(1995), that the showing necessary to obtain discovery should
itself be a significant barrier to the litigation of insubstantial
claims.
A selective-prosecution claim asks a court to exercise judicial
power over a "special province" of the Executive.
Heckler v.
Chaney, 470 U.
S. 821, 832 (1985). The Attorney General and United States
Attorneys retain" 'broad discretion'" to enforce the Nation's
criminal laws.
Wayte v.
United States, 470 U. S. 598, 607 (1985)
(quoting
United States v.
Goodwin, 457 U. S. 368, 380, n. 11
(1982)). They have this latitude because they are designated by
statute as the President's delegates to help him discharge his
constitutional responsibility to "take Care that the Laws be
faithfully executed." U. S. Const., Art. II, §3; see 28 U. S. C.
§§516, 547. As a result, "[t]he presumption of regularity supports"
their prosecutorial decisions and, "in the absence of clear
evidence to the contrary, courts presume that they have properly
discharged their official duties."
United States v.
Chemical Foundation, Inc., 272 U. S. 1, 14-15 (1926).
In the ordinary case, "so long as the prosecutor has probable cause
to believe that the accused committed an offense defined by
statute, the decision whether or not to prosecute, and what charge
to file or bring before a grand jury, generally rests entirely in
his discretion."
Bordenkircher v.
Hayes, 434 U. S. 357, 364
(1978).
Of course, a prosecutor's discretion is "subject to
constitutional constraints."
United States v.
Batchelder, 442 U. S. 114, 125
(1979). One of these constraints, imposed by the equal protection
component of the Due Process Clause of the Fifth Amendment,
Bolling v.
Sharpe, 347 U. S. 497, 500
(1954), is that the decision whether to prosecute may not be based
on "an unjustifiable standard such as race, religion, or other
arbitrary classification,"
Oyler v.
Boles, 368 U. S. 448, 456
(1962). A defendant may demonstrate that the administration of a
criminal law is "directed so exclusively against a particular class
of persons ... with a mind so unequal and
465
oppressive" that the system of prosecution amounts to "a
practical denial" of equal protection of the law.
Yick Wo v.
Hopkins, 118
U. S. 356, 373 (1886).
In order to dispel the presumption that a prosecutor has not
violated equal protection, a criminal defendant must present "clear
evidence to the contrary."
Chemical Foundation, supra, at
14-15. We explained in
Wayte why courts are "properly
hesitant to examine the decision whether to prosecute." 470 U. S.,
at 608. Judicial deference to the decisions of these executive
officers rests in part on an assessment of the relative competence
of prosecutors and courts. "Such factors as the strength of the
case, the prosecution's general deterrence value, the Government's
enforcement priorities, and the case's relationship to the
Government's overall enforcement plan are not readily susceptible
to the kind of analysis the courts are competent to undertake."
Id., at 607. It also stems from a concern not to
unnecessarily impair the performance of a core executive
constitutional function. "Examining the basis of a prosecution
delays the criminal proceeding, threatens to chill law enforcement
by subjecting the prosecutor's motives and decisionmaking to
outside inquiry, and may undermine prosecutorial effectiveness by
revealing the Government's enforcement policy."
Ibid.
The requirements for a selective-prosecution claim draw on
"ordinary equal protection standards."
Id., at 608. The
claimant must demonstrate that the federal prosecutorial policy
"had a discriminatory effect and that it was motivated by a
discriminatory purpose."
Ibid.; accord,
Oyler, supra,
at 456. To establish a discriminatory effect in a race case, the
claimant must show that similarly situated individuals of a
different race were not prosecuted. This requirement has been
established in our case law since
Ah Sin v.
Wittman,
198 U. S. 500
(1905). Ah Sin, a subject of China, petitioned a California state
court for a writ of habeas corpus, seeking discharge from
imprisonment under a San Francisco County
466
ordinance prohibiting persons from setting up gambling tables in
rooms barricaded to stop police from entering.
Id., at 503.
He alleged in his habeas petition "that the ordinance is enforced
'solely and exclusively against persons of the Chinese race and not
otherwise.'''
Id., at 507. We rejected his contention that
this averment made out a claim under the Equal Protection Clause,
because it did not allege "that the conditions and practices to
which the ordinance was directed did not exist exclusively among
the Chinese, or that there were other offenders against the
ordinance than the Chinese as to whom it was not enforced."
Id., at 507-508.
The similarly situated requirement does not make a
selective-prosecution claim impossible to prove. Twenty years
before
Ah Sin, we invalidated an ordinance, also adopted by
San Francisco, that prohibited the operation of laundries in wooden
buildings.
Yick Wo, 118 U. S., at 374. The plaintiff in
error successfully demonstrated that the ordinance was applied
against Chinese nationals but not against other laundry-shop
operators. The authorities had denied the applications of 200
Chinese subjects for permits to operate shops in wooden buildings,
but granted the applications of 80 individuals who were not Chinese
subjects to operate laundries in wooden buildings "under similar
conditions."
Ibid. We explained in
Ah Sin why the
similarly situated requirement is necessary:
"No latitude of intention should be indulged in a case like
this. There should be certainty to every intent. Plaintiff in error
seeks to set aside a criminal law of the State, not on the ground
that it is unconstitutional on its face, not that it is
discriminatory in tendency and ultimate actual operation as the
ordinance was which was passed on in the Yick Wo case, but
that it was made so by the manner of its administration. This is a
matter of proof, and no fact should be omitted to make it out
completely, when the power of a Federal court is in-
467
voked to interfere with the course of criminal justice of a
State." 198 U. S., at 508 (emphasis added).
Although
Ah Sin involved federal review of a state
conviction, we think a similar rule applies where the power of a
federal court is invoked to challenge an exercise of one of the
core powers of the Executive Branch of the Federal Government, the
power to prosecute.
Respondents urge that cases such as
Batson v.
Kentucky, 476
U. S. 79 (1986), and
Hunter v.
Underwood,
471 U. S. 222
(1985), cut against any absolute requirement that there be a
showing of failure to prosecute similarly situated individuals. We
disagree. In
Hunter, we invalidated a state law
disenfranchising persons convicted of crimes involving moral
turpitude.
Id., at 233. Our holding was consistent with
ordinary equal protection principles, including the similarly
situated requirement. There was convincing direct evidence that the
State had enacted the provision for the purpose of disenfranchising
blacks,
id., at 229-231, and indisputable evidence that the
state law had a discriminatory effect on blacks as compared to
similarly situated whites: Blacks were" 'by even the most modest
estimates at least 1.7 times as likely as whites to suffer
disfranchisement under'" the law in question,
id., at 227
(quoting
Underwood v.
Hunter, 730
F.2d 614, 620 (CAll 1984)).
Hunter thus affords no
support for respondents' position.
In
Batson, we considered "[t]he standards for assessing a
prima facie case in the context of discriminatory selection of the
venire" in a criminal trial. 476 U. S., at 96. We required a
criminal defendant to show "that the prosecutor has exercised
peremptory challenges to remove from the venire members of the
defendant's race" and that this fact, the potential for abuse
inherent in a peremptory strike, and "any other relevant
circumstances raise an inference that the prosecutor used that
practice to exclude the veniremen from the petit jury on account of
their race."
Ibid. During jury selection, the entire
res
gestae take place in front of the trial
468
judge. Because the judge has before him the entire venire, he is
well situated to detect whether a challenge to the seating of one
juror is part of a "pattern" of singling out members of a single
race for peremptory challenges. See
id., at 97. He is in a
position to discern whether a challenge to a black juror has
evidentiary significance; the significance may differ if the venire
consists mostly of blacks or of whites. Similarly, if the defendant
makes out a prima facie case, the prosecutor is called upon to
justify only decisions made in the very case then before the court.
See
id., at 97-98. The trial judge need not review
prosecutorial conduct in relation to other venires in other
cases.
Having reviewed the requirements to prove a selectiveprosecution
claim, we turn to the showing necessary to obtain discovery in
support of such a claim. If discovery is ordered, the Government
must assemble from its own files documents which might corroborate
or refute the defendant's claim. Discovery thus imposes many of the
costs present when the Government must respond to a prima facie
case of selective prosecution. It will divert prosecutors'
resources and may disclose the Government's prosecutorial strategy.
The justifications for a rigorous standard for the elements of a
selective-prosecution claim thus require a correspondingly rigorous
standard for discovery in aid of such a claim.
The parties, and the Courts of Appeals which have considered the
requisite showing to establish entitlement to discovery, describe
this showing with a variety of phrases, like "colorable basis,"
"substantial threshold showing," Tr. of Oral Arg. 5, "substantial
and concrete basis," or "reasonable likelihood," Brief for
Respondents Martin et al. 30. However, the many labels for this
showing conceal the degree of consensus about the evidence
necessary to meet it. The Courts of Appeals "require some evidence
tending to show the existence of the essential elements of the
defense," discriminatory effect and discriminatory intent.
United States v.
Berrios, 501 F.2d
1207, 1211 (CA2 1974).
469
In this case we consider what evidence constitutes "some
evidence tending to show the existence" of the discriminatory
effect element. The Court of Appeals held that a defendant may
establish a colorable basis for discriminatory effect without
evidence that the Government has failed to prosecute others who are
similarly situated to the defendant. 48 F. 3d, at 1516. We think it
was mistaken in this view. The vast majority of the Courts of
Appeals require the defendant to produce some evidence that
similarly situated defendants of other races could have been
prosecuted, but were not, and this requirement is consistent with
our equal protection case law.
United States v.
Parham, 16 F.3d
844, 846847 (CA8 1994);
United States v.
Fares,
978 F.2d
52, 59-60 (CA2 1992);
United States v.
Peete,
919 F.2d
1168, 1176 (CA6 1990); C.
E. Carlson, Inc. v.
SEC, 859 F.2d
1429, 1437-1438 (CAlO 1988);
United States v.
Greenwood, 796 F.2d
49,52-53 (CA4 1986);
United States v.
Mitchell,
778 F.2d
1271, 1277 (CA7 1985). As the three-judge panel explained,
"'[s]elective prosecution' implies that a selection has taken
place." 21 F. 3d, at 1436.3
The Court of Appeals reached its decision in part because it
started "with the presumption that people of
all races
commit
all types of crimes-not with the premise that any
type of crime is the exclusive province of any particular racial or
ethnic group." 48 F. 3d, at 1516-1517. It cited no authority for
this proposition, which seems contradicted by the most recent
statistics of the United States Sentencing Commission. Those
statistics show: More than 90% of the persons sentenced in 1994 for
crack cocaine trafficking were black, United States Sentencing
Comm'n, 1994 Annual Report 107 (Table 45); 93.4% of convicted LSD
dealers were white,
ibid.; and 91% of those convicted for
pornography or prostitution were white,
id., at 41 (Table
13). Presumptions
3We reserve the question whether a defendant must satisfy the
similarly situated requirement in a case "involving direct
admissions by [prosecutors] of discriminatory purpose." Brief for
United States 15.
470
at war with presumably reliable statistics have no proper place
in the analysis of this issue.
The Court of Appeals also expressed concern about the
"evidentiary obstacles defendants face." 48 F. 3d, at 1514. But all
of its sister Circuits that have confronted the issue have required
that defendants produce some evidence of differential treatment of
similarly situated members of other races or protected classes. In
the present case, if the claim of selective prosecution were well
founded, it should not have been an insuperable task to prove that
persons of other races were being treated differently than
respondents. For instance, respondents could have investigated
whether similarly situated persons of other races were prosecuted
by the State of California and were known to federal law
enforcement officers, but were not prosecuted in federal court. We
think the required threshold-a credible showing of different
treatment of similarly situated persons-adequately balances the
Government's interest in vigorous prosecution and the defendant's
interest in avoiding selective prosecution.
In the case before us, respondents' "study" did not constitute
"some evidence tending to show the existence of the essential
elements of" a selective-prosecution claim.
Berrios, supra,
at 1211. The study failed to identify individuals who were not
black and could have been prosecuted for the offenses for which
respondents were charged, but were not so prosecuted. This omission
was not remedied by respondents' evidence in opposition to the
Government's motion for reconsideration. The newspaper article,
which discussed the discriminatory effect of federal drug
sentencing laws, was not relevant to an allegation of
discrimination in decisions to prosecute. Respondents' affidavits,
which recounted one attorney's conversation with a drug treatment
center employee and the experience of another attorney defending
drug prosecutions in state court, recounted hearsay and reported
personal conclusions based on anecdotal evidence. The judgment of
the Court of Appeals is therefore
471
reversed, and the case is remanded for proceedings consistent
with this opinion.
It is so ordered.
JUSTICE SOUTER, concurring.
I join the Court's opinion, but in its discussion of Federal
Rule of Criminal Procedure 16 only to the extent of its application
to the issue in this case.
JUSTICE GINSBURG, concurring.
I do not understand the Court to have created a "major
limitation" on the scope of discovery available under Federal Rule
of Criminal Procedure 16. See
post, at 475 (BREYER, J.,
concurring in part and concurring in judgment). As I see it, the
Court has decided a precise issue: whether the phrase "defendant's
defense," as used in Rule 16(a)(1)(C), encompasses allegations of
selective prosecution. I agree with the Court, for reasons the
opinion states, that subdivision (a)(l)(C) does not apply to
selective prosecution claims. The Court was not called upon to
decide here whether Rule 16(a)(1)(C) applies in any other context,
for example, to affirmative defenses unrelated to the merits. With
the caveat that I do not read today's opinion as precedent
foreclosing issues not tendered for review, I join the Court's
opinion.
JUSTICE BREYER, concurring in part and concurring in the
judgment.
I write separately because, in my view, Federal Rule of Criminal
Procedure 16 does not limit a defendant's discovery rights to
documents related to the Government's case in chief.
Ante,
at 462-463. The Rule says that "the government shall permit the
defendant to inspect and copy" certain physical items (I shall
summarily call them "documents") "which are material to the
preparation of the defendant's defense." Fed. Rule Crim. Proc.
16(a)(1)(C). A "defendant's defense" can take many forms, including
(1) a simple re-
472
Opinion of BREYER, J.
sponse to the Government's case in chief, (2) an affirmative
defense unrelated to the merits (such as a Speedy Trial Act claim),
(3) an unrelated claim of constitutional right, (4) a foreseeable
surrebuttal to a likely Government rebuttal, and others. The Rule's
language does not limit its scope to the first item on this list.
To interpret the Rule in this limited way creates a legal
distinction that, from a discovery perspective, is arbitrary. It
threatens to create two full parallel sets of criminal discovery
principles. And, as far as I can tell, the interpretation lacks
legal support.
The Court bases its interpretation upon what it says is a
"perceptible symmetry,"
ante, at 462, between two phrases in
Rule 16(a)(1)(C)-the phrase "material to the preparation of the
defendant's defense," and the next phrase, "intended for use by the
government as evidence in chief at the trial." To test the Court's
argument, consider these two phrases in context. The Rule says:
"Upon request of the defendant the government shall permit the
defendant to inspect and copy [documents and other items] ... which
[1] are material to the preparation of the defendant's defense or
[2] are intended for use by the government as evidence in chief at
the trial, or [3] were obtained from or belong to the defendant."
Fed. Rule Crim. Proc. 16(a)(1)(C).
Though symmetry may reside in the eye of the beholder, I can
find no relevant symmetry here. Rather, the language suggests a
simple three-part categorization of the documents and other
physical items that the Rule requires the Government to make
available to the defendant. From a purely linguistic perspective,
there is no more reason to import into the first category a
case-in-chief-related limitation (from the second category) than
some kind of defendant's-belongingsrelated limitation (from the
third category).
Rule 16 creates these three categories for a reason that belies
"symmetry"-namely, to specify two sets of items (the
473
Government's case in chief evidence, the defendant's belongings)
that the Government must make available to the defendant without a
preliminary showing of "materiality." The Rule's first category
creates a residual classification (items "material to the
preparation of the defendant's defense") that require a preliminary
"materiality" showing. The Committee thought, however, that
"[l]imiting the rule to situations in which the defendant can show
that the evidence is material seems unwise .... For this reason
subdivision (a)(l)(C) also contains language to compel disclosure
if the government intends to use the property as evidence at the
trial or if the property was obtained from or belongs to the
defendant." Advisory Committee's Notes on Fed. Rule Crim. Proc. 16,
18 U. S. C. App., p. 762 (second and third categories added to
specify that,
without a special showing of materiality,
certain items are almost always "material") (citing 1 C. Wright,
Federal Practice and Procedure § 254, p. 510, n. 58, p. 513, n. 70
(1969)). Nothing in the Notes, or in the Rule's language, suggests
that the residual category of items "material to the preparation of
the defendant's defense," means to cover only those items related
to the case in chief.
The only other reason the majority advances in support of its
"case in chief" limitation concerns a later part of the Rule,
subdivision 16(a)(2). As relevant here, that subdivision exempts
Government attorney work product from certain of Rule 16's
disclosure requirements. In the majority's view, since (1) a
defendant asserting a valid "selective prosecution" defense would
likely need prosecution work product to make his case, but (2) the
Rule exempts prosecution work product from discovery, then (3) the
Rule must have some kind of implicit limitation (such as a "case in
chief" limitation) that makes it irrelevant to defense efforts to
assert "selective prosecution" defenses.
The majority's conclusion, however, does not follow from its
premises. For one thing, Rule 16's work-product excep-
474
Opinion of BREYER, J.
tion may itself contain implicit exceptions. After all, "[t]he
privilege derived from the work-product doctrine is not absolute."
United States v.
Nobles, 422 U. S. 225, 239
(1975); see also 8 C. Wright, A. Miller, & R. Marcus, Federal
Practice and Procedure § 2022, p. 324 (2d ed. 1994) (in civil
context, work product "is discoverable only on a substantial
showing of 'necessity or justification''') (quoting
Hickman
v.
Taylor, 329
U. S. 495, 510 (1947)); J. Ghent, Development, Since Hickman v.
Taylor, of Attorney's "Work Product" Doctrine, 35 A. L. R. 3d 412,
465-469, § 25 (1971) (in civil context, work-product protection is
not absolute, but is a "qualified privilege or immunity"). To the
extent such a reading permits a defendant to obtain "work product"
in an appropriate case (say, with a strong prima facie showing of
selective prosecution), the Court's problem does not exist. Of
course, to read the work-product exception as containing some such
implicit exception itself represents a departure from the Rule's
literal language. But, is it not far easier to believe the Rule's
authors intended some such small implicit exception to an
exception, consistent with the language and purpose of the Rule,
than that they intended the very large exception created by the
Court?
For another thing, even if one reads the work-product exception
literally, the Court's problem disappears as long as courts can
supplement Rule 16 discovery with discovery based upon
other legal principles. The language of the work-product
exception suggests the possibility of such supplementation, for it
says, not that work product is "exemp[t]" from discovery,
ante, at 462, but that
"this rule" does not authorize
discovery of the prosecutor's work product. Fed. Rule Civ. Proc.
16(a)(2). The Advisory Committee's Notes make clear that the
Committee believed that
other rules of law may authorize (or
require) discovery not mentioned in the Rule. See,
e.
g., Advisory Committee's Notes on Rule 16, 18 U. S. C. App.,
pp. 762, 763 (discussion of
Brady v.
Maryland,
373 U. S. 83
(1963), which the Rule does not cod-
475
ify); 18 U. S. C. App., p. 761 ("[Rule 16] is intended to
prescribe the minimum amount of discovery to which the parties are
entitled. It is not intended to limit the judge's discretion to
order broader discovery in appropriate cases"); see also 2 C.
Wright, Federal Practice and Procedure § 254, p. 81, and n. 60 (2d
ed. 1982) ("Because Brady is based on the Constitution, it
overrides court-made rules of procedure. Thus the work-product
immunity for discovery in Rule 16(a)(2) prohibits discovery under
Rule 16 but it does not alter the prosecutor's duty to disclose
material that is within Brady") (footnotes omitted). Of course, the
majority, in a sense, reads the Rule as permitting supplementation,
but it does more. It goes well beyond the
added (say,
constitutionally related) rule supplementation needed to overcome
its problem; instead, it
shrinks the Rule by unnecessarily
creating a major limitation on its scope.
Finally, and in any event, here the defendants sought discovery
of information that is not work product. See
ante, at 459.
Thus, we need not decide whether in an appropriate case it would be
necessary to find an implicit exception to the language of Rule
16(a)(2), or to find an independent constitutional source for the
discovery, or to look for some other basis.
In sum, neither the alleged "symmetry" in the structure of Rule
16(a)(1)(C), nor the work-product exception of Rule 16(a)(2),
supports the majority's limitation of discovery under Rule
16(a)(1)(C) to documents related to the Government's "case in
chief." Rather, the language and legislative history make clear
that the Rule's drafters meant it to provide a broad authorization
for defendants' discovery, to be supplemented if necessary in an
appropriate case. Whether or not one can
also find a basis
for this kind of discovery in other sources of law, Rule
16(a)(1)(C) provides
one such source, and we should consider
whether the defendants' discovery request satisfied the Rule's
requirement that the discovery be "material to the preparation of
the defendant's defense."
476
I believe that the defendants' request did not satisfy this
threshold. Were the "selective prosecution" defense valid in this
case-i.
e., were there "clear evidence,"
United
States v.
Chemical Foundation, Inc., 272 U. S. 1, 14 (1926),
that the Federal Government's prosecutorial policy "had a
discriminatory effect and ... was motivated by a discriminatory
purpose,"
Wayte v.
United States, 470 U. S. 598, 608
(1985), it should have been fairly easy for the defendants to find,
not only instances in which the Federal Government prosecuted
African-Americans, but also some instances in which the Federal
Government did not prosecute similarly situated caucasians. The
defendants' failure to do so, for the reasons the Court sets forth,
amounts to a failure to make the necessary threshold showing in
respect to materiality. See 2 C. Wright, Federal Practice and
Procedure § 254, pp. 66-67 (2d ed. 1982);
United States v.
Balk, 706 F.2d
1056, 1060 (CA9 1983);
United States v.
Johnson,
577 F.2d
1304, 1309 (CA5 1978);
United States v.
Murdock,
548 F.2d
599, 600 (CA51977).
JUSTICE STEVENS, dissenting.
Federal prosecutors are respected members of a respected
profession. Despite an occasional misstep, the excellence of their
work abundantly justifies the presumption that "they have properly
discharged their official duties."
United States v.
Chemical Foundation, Inc., 272 U. S. 1, 14-15 (1926).
Nevertheless, the possibility that political or racial animosity
may infect a decision to institute criminal proceedings cannot be
ignored.
Oy ler v.
Bo les, 368 U. S. 448, 456
(1962). For that reason, it has long been settled that the
prosecutor's broad discretion to determine when criminal charges
should be filed is not completely unbridled. As the Court notes,
however, the scope of judicial review of particular exercises of
that discretion is not fully defined. See
ante, at 469, n.
3.
477
The United States Attorney for the Central District of
California is a member and an officer of the bar of that District
Court. As such, she has a duty to the judges of that Court to
maintain the standards of the profession in the performance of her
official functions. If a District Judge has reason to suspect that
she, or a member of her staff, has singled out particular
defendants for prosecution on the basis of their race, it is surely
appropriate for the judge to determine whether there is a factual
basis for such a concern. I agree with the Court that Rule 16 of
the Federal Rules of Criminal Procedure is not the source of the
District Court's power to make the necessary inquiry. I disagree,
however, with its implicit assumption that a different, relatively
rigid rule needs to be crafted to regulate the use of this
seldomexercised inherent judicial power. See Advisory Committee's
Notes on Rule 16, 18 U. S. C. App., p. 761 (Rule 16 is "not
intended to limit the judge's discretion to order broader discovery
in appropriate cases").
The Court correctly concludes that in this case the facts
presented to the District Court in support of respondents' claim
that they had been singled out for prosecution because of their
race were not sufficient to prove that defense. Moreover, I agree
with the Court that their showing was not strong enough to give
them a
right to discovery, either under Rule 16 or under the
District Court's inherent power to order discovery in appropriate
circumstances. Like Chief Judge Wallace of the Court of Appeals,
however, I am persuaded that the District Judge did not abuse her
discretion when she concluded that the factual showing was
sufficiently disturbing to require some response from the United
States Attorney's Office. See
48 F.3d
1508, 1520-1521 (CA9 1995). Perhaps the discovery order was
broader than necessary, but I cannot agree with the Court's
apparent conclusion that no inquiry was permissible.
The District Judge's order should be evaluated in light of three
circumstances that underscore the need for judicial
478
vigilance over certain types of drug prosecutions. First, the
Anti-Drug Abuse Act of 1986 and subsequent legislation established
a regime of extremely high penalties for the possession and
distribution of so-called "crack" cocaine.1 Those provisions treat
one gram of crack as the equivalent of 100 grams of powder cocaine.
The distribution of 50 grams of crack is thus punishable by the
same mandatory minimum sentence of 10 years in prison that applies
to the distribution of 5,000 grams of powder cocaine.2 The
Sentencing Guidelines extend this ratio to penalty levels above the
mandatory minimums: For any given quantity of crack, the guideline
range is the same as if the offense had involved 100 times that
amount in powder cocaine.3 These penalties result in sentences for
crack offenders that average three to eight times longer than
sentences for comparable powder offenders.4 United States
Sentencing Commission, Special Report to Congress: Cocaine and
Federal Sentencing Policy 145 (Feb. 1995) (hereinafter Special
Report).
1100 Stat. 3207, 21 U. S. C. § 841
et seq.
2 Compare 21 U. S. C. § 841(b)(1)(A)(iii) with §
841(b)(1)(A)(ii). Similarly, a mandatory 5-year sentence is
prescribed for distribution of 500 grams of cocaine or 5 grams of
crack. Compare § 841(b)(1)(B)(ii) with § 841(b)(1)(B)(iii). Simple
possession of 5 grams of crack also produces a mandatory 5-year
sentence. The maximum sentence for possession of
any
quantity of other drugs is one year. § 844(a).
With one prior felony drug offense, the sentence for
distribution of 50 grams of crack is a mandatory 20 years to life.
§ 841(b)(1)(A). With two prior felony drug offenses, the sentence
is a mandatory life term without parole.
Ibid.
3 See United States Sentencing Commission, Guidelines Manual
§2Dl.l(c) (Nov. 1995) (USSG).
4 Under the Guidelines, penalties increase at a slower rate than
drug quantities. For example, 5 grams of heroin result in a base
offense level of 14 (15-21 months) while 10 grams of heroin (double
the amount) result in an offense level of 16 (21-27 months). USSG
§§ 2Dl.l(c)(13), (12). Thus, the 100-to-1 ratio does not translate
into sentences that are 100 times as long.
479
Second, the disparity between the treatment of crack cocaine and
powder cocaine is matched by the disparity between the severity of
the punishment imposed by federal law and that imposed by state law
for the same conduct. For a variety of reasons, often including the
absence of mandatory minimums, the existence of parole, and lower
baseline penalties, terms of imprisonment for drug offenses tend to
be substantially lower in state systems than in the federal system.
The difference is especially marked in the case of crack offenses.
The majority of States draw no distinction between types of cocaine
in their penalty schemes; of those that do, none has established as
stark a differential as the Federal Government. See
id., at
x, 129-138. For example, if respondent Hampton is found guilty, his
federal sentence might be as long as a mandatory life term. Had he
been tried in state court, his sentence could have been as short as
12 years, less worktime credits of half that amount.5
Finally, it is undisputed that the brunt of the elevated federal
penalties falls heavily on blacks. While 65% of the persons who
have used crack are white, in 1993 they
5 Hampton was charged with conspiracy to distribute, four counts
of crack distribution, and the use or carrying of a firearm in
relation to a drug crime. According to an information filed by the
Government, Hampton had three prior convictions for felony drug
offenses. See Information Establishing Prior Felony Narcotics
Convictions (June 24, 1992). Therefore, he potentially faces a
mandatory life sentence on the drug charges alone.
Under California law at the time of the offenses, possession for
sale of cocaine base involving 50 grams carried a penalty of
imprisonment for either three, four, or five years. Cal. Health
& Safety Code Ann. § 11351.5 (West 1988). If the defendant had
no prior convictions, he could be granted probation. § 11370. For
each prior felony drug conviction, the defendant received an
additional 3-year sentence. § 11370.2. Thus, with three priors and
the possibility of worktime reductions, see Cal. Penal Code Ann. §
2933 (West Supp. 1996), Hampton could have served as little as six
years under California law. Since the time of the offenses,
California has raised several of these penalties, but the new
punishments could not be applied to respondents.
480
represented only 4% of the federal offenders convicted of
trafficking in crack. Eighty-eight percent of such defendants were
black.
Id., at 39, 161. During the first 18 months of full
guideline implementation, the sentencing disparity between black
and white defendants grew from preguideline levels: Blacks on
average received sentences over 40% longer than whites. See Bureau
of Justice Statistics, Sentencing in the Federal Courts: Does Race
Matter? 6-7 (Dec. 1993). Those figures represent a major threat to
the integrity of federal sentencing reform, whose main purpose was
the elimination of disparity (especially racial) in sentencing. The
Sentencing Commission acknowledges that the heightened crack
penalties are a "primary cause of the growing disparity between
sentences for Black and White federal defendants." Special Report
163.
The extraordinary severity of the imposed penalties and the
troubling racial patterns of enforcement give rise to a special
concern about the fairness of charging practices for crack
offenses. Evidence tending to prove that black defendants charged
with distribution of crack in the Central District of California
are prosecuted in federal court, whereas members of other races
charged with similar offenses are prosecuted in state court,
warrants close scrutiny by the federal judges in that district. In
my view, the District Judge, who has sat on both the federal and
the state benches in Los Angeles, acted well within her discretion
to call for the development of facts that would demonstrate what
standards, if any, governed the choice of forum where similarly
situated offenders are prosecuted.
Respondents submitted a study showing that of all cases
involving crack offenses that were closed by the Federal Public
Defender's Office in 1991, 24 out of 24 involved black defendants.
To supplement this evidence, they submitted affidavits from two of
the attorneys in the defense team. The first reported a statement
from an intake coordinator at a local drug treatment center that,
in his experience, an
481
equal number of crack users and dealers were caucasian as
belonged to minorities. App. 138. The second was from David R.
Reed, counsel for respondent Armstrong. Reed was both an active
court-appointed attorney in the Central District of California and
one of the directors of the leading association of criminal defense
lawyers who practice before the Los Angeles County courts. Reed
stated that he did not recall "ever handling a [crack] cocaine case
involving non-black defendants" in federal court, nor had he even
heard of one.
Id., at 140. He further stated that "[t]here
are many crack cocaine sales cases prosecuted in state court that
do involve racial groups other than blacks."
Id., at
141 (emphasis in original).
The majority discounts the probative value of the affidavits,
claiming that they recounted "hearsay" and reported "personal
conclusions based on anecdotal evidence."
Ante, at 470. But
the Reed affidavit plainly contained more than mere hearsay; Reed
offered information based on his own extensive experience in both
federal and state courts. Given the breadth of his background, he
was well qualified to compare the practices of federal and state
prosecutors. In any event, the Government never objected to the
admission of either affidavit on hearsay or any other grounds. See
48 F. 3d, at 1518, n. 8. It was certainly within the District
Court's discretion to credit the affidavits of two members of the
bar of that Court, at least one of whom had presumably acquired a
reputation by his frequent appearances there, and both of whose
statements were made on pains of perjury.
The criticism that the affidavits were based on "anecdotal
evidence" is also unpersuasive. I thought it was agreed that
defendants do not need to prepare sophisticated statistical studies
in order to receive mere discovery in cases like this one.
Certainly evidence based on a drug counselor's personal
observations or on an attorney's practice in two sets of courts,
state and federal, can" 'ten[d] to show the existence'" of a
selective prosecution.
Ante, at 468.
482
Even if respondents failed to carry their burden of showing that
there were individuals who were not black but who could have been
prosecuted in federal court for the same offenses, it does not
follow that the District Court abused its discretion in ordering
discovery. There can be no doubt that such individuals exist, and
indeed the Government has never denied the same. In those
circumstances, I fail to see why the District Court was unable to
take judicial notice of this obvious fact and demand information
from the Government's files to support or refute respondents'
evidence. The presumption that some whites are prosecuted in state
court is not "contradicted" by the statistics the majority cites,
which show only that high percentages of blacks are
convicted of certain federal crimes, while high percentages
of whites are convicted of other federal crimes. See
ante,
at 469-470. Those figures are entirely consistent with the
allegation of selective prosecution. The relevant comparison,
rather, would be with the percentages of blacks and whites who
commit those crimes. But, as discussed above, in the case of
crack far greater numbers of whites are believed guilty of using
the substance. The District Court, therefore, was entitled to find
the evidence before it significant and to require some explanation
from the Government.6
6 Also telling was the Government's response to respondents'
evidentiary showing. It submitted a list of more than 3,500
defendants who had been charged with federal narcotics violations
over the previous three years. It also offered the names of 11
nonblack defendants whom it had prosecuted for crack offenses. All
11, however, were members of other racial or ethnic minorities. See
48 F.3d
1508, 1511
(CA9 1995). The District Court was authorized
to draw adverse inferences from the Government's inability to
produce a single example of a white defendant, especially when the
very purpose of its exercise was to allay the court's concerns
about the evidence of racially selective prosecutions. As another
court has said: "Statistics are not, of course, the whole answer,
but nothing is as emphatic as zero .... "
United States v.
Hinds County School Ed., 417 F.2d
852, 858
(CA5 1969)
(per curiam).
483
In sum, I agree with the Sentencing Commission that "[w]hile the
exercise of discretion by prosecutors and investigators has an
impact on sentences in almost all cases to some extent, because of
the 100-to-1 quantity ratio and federal mandatory minimum
penalties, discretionary decisions in cocaine cases often have
dramatic effects." Special Report 138.7 The severity of the penalty
heightens both the danger of arbitrary enforcement and the need for
careful scrutiny of any colorable claim of discriminatory
enforcement. Cf.
McCleskey v.
Kemp, 481 U. S. 279, 366 (1987)
(STEVENS, J., dissenting). In this case, the evidence was
sufficiently disturbing to persuade the District Judge to order
discovery that might help explain the conspicuous racial pattern of
cases before her court. I cannot accept the majority's conclusion
that the District Judge either exceeded her power or abused her
discretion when she did so. I therefore respectfully dissent.
7 For this and other reasons, the Sentencing Commission in its
Special Report to Congress "strongly recommend[ed] against a
100-to-1 quantity ratio." Special Report 198. The Commission
shortly thereafter, by a 4-to-3 vote, amended the Guidelines so as
to equalize the treatment of crack and other forms of cocaine, and
proposed modification of the statutory mandatory minimum penalties
for crack offenses. See Statement of Commission Majority in Support
of Recommended Changes in Cocaine and Federal Sentencing Policy
(May 1, 1995). In October 1995, Congress overrode the Sentencing
Commission's Guideline amendments. See Pub. L. 104-38, 109 Stat.
334. Nevertheless, Congress at the same time directed the
Commission to submit recommendations regarding changes to the
statutory and guideline penalties for cocaine distribution,
including specifically "revision of the drug quantity ratio of
crack cocaine to powder cocaine." § 2(a).
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