United States v. Rosemary MacDonald Houston

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). 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 elements. We have jurisdiction over this federal crime and affirm.

I

On October 15, 2001, Trina Bradford was found dead in her home on the Blackfeet Indian Reservation in Browning, Montana. Subsequent forensic investigation revealed that Bradford had numerous controlled substances in her blood and mine, including a lethal concentration of methadone. The methadone was determined to have come from a prescription bottle bearing the defendant’s name that was found at the scene of Bradford’s death.

Houston was indicted for distribution of a controlled substance resulting in death under § 841(a)(1) and (b)(1)(C). She was…