Background
Johntavis Matlock sold Lindsey Wiley a heroin-fentanyl mixture on December 11, 2020. Wiley ingested some while meeting with Matlock and returned home, where her family later found her unconscious, barely breathing, and with a purple face. Paramedics observed signs of an opioid overdose, and Wiley regained consciousness within a minute after receiving Narcan. She told medical personnel that she had used heroin.
Later that night, Wiley texted Matlock that she had overdosed and stopped breathing, explaining that she had used only what Matlock saw her use. Matlock admitted at trial that he sold her heroin that evening but disputed that it caused her overdose, pointing to her diabetes, prescription medications, drug paraphernalia in her bedroom, the absence of toxicology testing, and the time between ingestion and her collapse.
A jury convicted Matlock of distributing a controlled substance resulting in serious bodily injury, possessing a firearm as a felon, and possessing a controlled substance, while acquitting him of a separate count alleging that a later distribution caused Wiley’s death. The district court sentenced him to 420 months in prison. On appeal, Matlock challenged only the serious-bodily-injury conviction, arguing that the government failed to prove his drugs were a but-for cause of Wiley’s December overdose.
The Court’s Holding
The Seventh Circuit affirmed. Viewing the trial record in the light most favorable to the government, the court held that a rational jury could find beyond a reasonable doubt that Wiley would not have overdosed but for the heroin Matlock supplied. The supporting evidence included Matlock’s admission that he sold Wiley heroin, Wiley’s statements identifying heroin as what she had taken, her text saying she had used only what Matlock saw her use, the timing of her collapse, and Matlock’s responses to her overdose report.
Medical evidence also supported the verdict. A paramedic testified that Wiley displayed opioid-overdose symptoms and regained consciousness immediately after receiving Narcan. He further testified that Narcan would not have revived her if diabetic shock had caused her condition. The court declined to reweigh Matlock’s competing theories about other drugs, prescription interactions, diabetes, or the interval before the overdose because assessing the evidence and witness credibility belonged to the jury.
The court rejected Matlock’s contention that his heroin had to be the independently sufficient or definitive cause of the overdose. Under the governing but-for standard, the enhancement can apply when the distributed drug combines with other factors and supplies the incremental effect that produces the injury—the “straw that broke the camel’s back.” The district court properly instructed the jury on that standard.
Key Takeaways
- A conviction under 21 U.S.C. § 841(b)(1)(C) for distribution resulting in serious bodily injury requires proof that the distributed drug was a but-for cause of the injury.
- The government was not required to prove that Matlock’s heroin was the overdose’s sole or independently sufficient cause; it was enough to prove the overdose would not have occurred without its incremental effect.
- Wiley’s statements and texts, Matlock’s admission, the timing of events, her opioid-overdose symptoms, and her immediate response to Narcan provided sufficient evidence of causation.
Why It Matters
The decision illustrates that the government may establish but-for causation under the serious-bodily-injury enhancement through circumstantial evidence, victim statements, admissions, and clinical observations even without contemporaneous toxicology testing. The existence of possible contributing conditions or substances does not defeat the enhancement when sufficient evidence permits the jury to conclude that the defendant’s drug pushed the victim “over the edge.”
It also reinforces the demanding standard governing sufficiency challenges: an appellate court does not reassess credibility or choose among competing factual theories when the record, viewed favorably to the prosecution, supports the jury’s verdict.