Case Explained: USA V. TULALI

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-08-14 Docket: 4:23-cr-00003-SLG-KFR-1 The Ninth Circuit affirmed the defendant’s jury conviction for distribution of a controlled substance resulting in death in violation of 21 U.S.C. § 841(a)(1), (b)(1)(C). The court rejected the defendant’s argument that Supreme Court decisions in *Burrage v. United States*, *Rehaif v. United States*, and *Ruan v. United States* clearly irreconcilably undercut the Ninth Circuit’s precedent in *United States v. Houston*, which holds that a defendant need not intend or foresee death for liability under this statute. The panel determined that *Burrage* addressed but-for causation rather than intent, while *Rehaif* and *Ruan* applied mental state requirements to separate wrongful from innocent acts, a distinction the court found inapplicable here because knowingly distributing controlled substances is inherently wrongful regardless of foreseeability. Regarding sufficiency of the evidence, the court applied the *Jackson v. Virginia* standard, concluding that viewing the record in the light most favorable to the prosecution, a rational trier of fact could find beyond a reasonable doubt that the fentanyl pills sold by the defendant were the but-for cause of the victim’s death based on testimony and text messages tracing the drugs from the defendant to the victim. As a result, the judgment of conviction is upheld. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.