Controlled Substances
Unlawful delivery of methamphetamine
Notes of Decisions
Unlawful delivery of methamphetamine is federal controlled substance offense for purposes of determining base offense level at sentencing by federal district court. U.S. v. Crum, 934 F3d 963 (9th Cir. 2019), cert. denied, Crum v. U.S., 140 S Ct 2629, 206 L Ed 2d 510 (2020)
Where defendant possessed small quantity of methamphetamine consistent with personal use, defendant’s possession of “tools of the trade,” such as scale and Ziploc baggies, is insufficient to prove attempted transfer of methamphetamine. State v. O’Hare, 309 Or App 357, 481 P3d 953 (2021)