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Ruan v. United States

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Supreme Court of the United States
Ruan v. United States
Term: 2021
Important Dates
Argued: March 1, 2022
Decided: June 27, 2022
Outcome
Vacated and remanded
Vote
9-0
Majority
Stephen Breyer • Chief Justice John G. Roberts • Sonia Sotomayor • Elena Kagan • Neil Gorsuch • Brett Kavanaugh
Concurring
Samuel Alito (in judgment) • Clarence Thomas (in judgment) • Amy Coney Barrett (in judgment)


Ruan v. United States is a case that was decided by the Supreme Court of the United States on June 27, 2022, during the court's October 2021-2022 term. The case was argued before the court on March 1, 2022. It was consolidated with Kahn v. United States.

The court vacated the decisions of the U.S. Court of Appeals for the 11th Circuit and U.S. Court of Appeals for the 10th Circuit and remanded the cases for further proceedings in a 9-0 ruling, holding that in order for a defendant to be convicted for unauthorized distribution of controlled substances under §841 of the Controlled Substances Act, the government must prove the defendant knowingly or intentionally acted in an unauthorized manner. Justice Stephen Breyer delivered the court's majority opinion. Justice Samuel Alito wrote an opinion concurring in the judgment, joined by Justices Clarence Thomas and Amy Coney Barrett.[1] Click here for more information about the ruling.

HIGHLIGHTS
  • The case: In both Ruan v. United States and Kahn v. United States, medical doctors were appealing their convictions for unlawful distribution of controlled substances under the U.S. Controlled Substances Act (CSA) after they were found to have prescribed narcotics outside the usual course of professional practice. Both defendant doctors attempted to use a good faith defense to counter the charges against them at trial and, after their convictions, appealed the way in which the trial judges instructed, or failed to instruct, the jury on the defense. On appeal to the U.S. Supreme Court, petitioners Ruan and Kahn asked the court to weigh in on the standard and elements required to assert a good faith defense under the CSA.[2][3] Click here to learn more about the cases' background details.
  • The issue: The cases concerned the good faith defense available to defendants charged under the U.S. Controlled Substances Act.
  • The question presented: "[W]hether a physician alleged to have prescribed controlled substances outside the usual course of professional practice may be convicted under Section 841(a)(1) without regard to whether, in good faith, he “reasonably believed” or “subjectively intended” that his prescriptions fall within that course of professional practice."[2]
  • The outcome: The court vacated and remanded the holdings of the courts of appeals.


    • Ruan v. United States came on a writ of certiorari to the United States Court of Appeals for the 11th Circuit. Click here to review the lower court's opinion.[4]
    Kahn v. United States came on a writ of certiorari to the United States Court of Appeals for the 10th Circuit. Click here to review the lower court's opinion.[5]

    Timeline

    The following timeline details key events in Ruan v. United States:

    • June 27, 2022: The U.S. Supreme Court vacated and remanded the courts of appeals' decisions.
    • March 1, 2022: The U.S. Supreme Court heard oral argument.
    • November 5, 2021: The U.S. Supreme Court agreed to hear the case.
    • April 5, 2021: Xiulu Ruan appealed to the U.S. Supreme Court.
    • July 10, 2020: The U.S. Court of Appeals for the 11th Circuit affirmed Dr. Xiulu Ruan's convictions on all counts except one. The court vacated Ruan's conviction and remanded the case to the U.S. District Court for the Southern District of Alabama for re-sentencing on one count related to Ruan's conviction for taking kickbacks.[4]

    The following timeline details key events in Kahn v. United States:

    • June 27, 2022: The U.S. Supreme Court vacated and remanded the courts of appeals' decisions.
    • March 1, 2022: The U.S. Supreme Court heard oral argument.
    • November 5, 2021: The U.S. Supreme Court agreed to hear the case.
    • July 26, 2021: Shakeel Kahn appealed to the U.S. Supreme Court.
    • February 25, 2021: The U.S. Court of Appeals for the 10th Circuit affirmed Dr. Shakeel Kahn's convictions.[5]

    Background

    The U.S. Supreme Court consolidated Ruan v. United States and Kahn v. United States to be heard together for one hour total of oral argument. Both cases involved medical doctors who were convicted of unlawful distribution of controlled substances under the U.S. Controlled Substances Act (CSA) after they were found to have prescribed narcotics outside the usual course of professional practice. Both cases present questions related to the standard and elements required for a good faith defense to the charge of unlawful distribution of controlled substances under the CSA.[4][5]

    Prescribing controlled substances under the Controlled Substances Act (CSA)

    Registered healthcare professionals can legally prescribe certain controlled substances under the CSA so long as the drugs are "prescribed for a legitimate medical purpose within the usual course of professional practice."[4][6] Controlled substances are those drugs that the CSA places into five schedules based on their potential for abuse and perceived medical value: Schedule I through Schedule V. Schedule I drugs cannot be legally prescribed by a medical doctor and include substances like heroin, LSD, marijuana, and ecstasy. Schedule II through Schedule IV drugs must be prescribed by a doctor. Schedule II substances include opioids such as morphine, fentanyl, and hydrocodone.[4]

    Ruan v. United States

    Dr. Xiulu Ruan and his medical partner, Dr. John Patrick Couch, were tried in the United States District Court for the Southern District of Alabama for various offenses related to the running of their medical practice and prescribing of prescription drugs, including charges of unlawful distribution of controlled substances under the CSA. During his trial, Ruan asked the judge to instruct the jury that good faith was a defense to the charges of unlawful distribution under the CSA. The judge rejected Ruan's request, as it was the 11th Circuit's position that the good faith instruction was available only to defendants whose conduct was deemed to be within professional norms.[2] After a seven-week trial, Ruan was convicted on a number of counts, including those relevant to his appeal to the Supreme Court: 1) Together with Couch, he was convicted of "conspiring to violate the Controlled Substances Act, 21 U.S.C. §§ 846 & 841(a)(1), by dispensing Schedule II drugs, fentanyl, and Schedule III drugs outside the usual course of professional practice and without a legitimate medical purpose," and, 2) individually, he was convicted of "multiple counts of substantive drug distribution in violation of the Controlled Substances Act, 21 U.S.C. § 841(a)(1)."[4] Ruan appealed his convictions to the United States Court of Appeals for the 11th Circuit, which affirmed all but one of Ruan's convictions related to taking kickbacks.[4]

    On appeal to the U.S. Supreme Court, Ruan asked the court to consider "whether and to what extent a physician charged with prescribing medication in violation of the CSA may assert a 'good faith' defense."[2] In the petition for a writ of certiorari, Ruan stated that in order to prevent doctors from being convicted under the CSA for merely negligent conduct, the 1st, 2nd, 4th, 6th, 7th, and 9th Circuits all established some version of a good faith defense where the government must prove that the defendant physician either did not reasonably believe or subjectively intend for the prescriptions to fall within professional standards. As the 11th Circuit does not provide for either version of the defense, Ruan asked the Supreme Court to weigh in on what the CSA requires.[2]

    Kahn v. United States

    Like Ruan, Dr. Shakeel Kahn was convicted after a jury trial of various offenses, including unlawful distribution of controlled substances under the CSA for prescribing narcotics outside the usual course of professional practice. In his appeal to the United States Court of Appeals for the 10th Circuit, Kahn alleged the trial court erred by instructing the jury the defendant's good faith must be reasonable—an objective standard that does not require the defendant to personally know or intend for his actions to be outside professional practice. Instead, Kahn argued that the jury should have been instructed to consider Kahn's good faith defense by what he personally knew or intended—a subjective standard. The 10th Circuit rejected this argument, holding that the CSA required the government to prove either that a defendant doctor: "(1) subjectively knew a prescription was issued not for a legitimate medical purpose; or (2) issued a prescription that was objectively not in the usual course of professional practice."[5]

    On appeal to the U.S. Supreme Court, Kahn asked the court to weigh in on which standard—objective, subjective, or both—should be applied to a defendant's good faith defense.[5]

    Question presented

    The petitioner presented the following question to the court:[2]

    Question presented:
    “ [W]hether a physician alleged to have prescribed controlled substances outside the usual course of professional practice may be convicted under Section 841(a)(1) without regard to whether, in good faith, he “reasonably believed” or “subjectively intended” that his prescriptions fall within that course of professional practice.[7] ”

    Oral argument

    Audio

    Audio of oral argument:[8]



    Transcript

    Transcript of oral argument:[9]

    Outcome

    The court vacated the decisions of the U.S. Court of Appeals for the 11th Circuit and U.S. Court of Appeals for the 10th Circuit and remanded the cases for further proceedings in a 9-0 ruling, holding that in order for a defendant to be convicted for unauthorized distribution of controlled substances under §841 of the Controlled Substances Act, the government must prove the defendant knowingly or intentionally acted in an unauthorized manner. Justice Stephen Breyer delivered the court's majority opinion. Justice Samuel Alito wrote an opinion concurring in the judgment, joined by Justices Clarence Thomas and Amy Coney Barrett.[1]

    Text of the opinion

    Read the full opinion here.

    October term 2021-2022

    See also: Supreme Court cases, October term 2021-2022

    The Supreme Court began hearing cases for the term on October 4, 2021. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[10]

    The court agreed to hear 68 cases during its 2021-2022 term.[11] Four cases were dismissed and one case was removed from the argument calendar.[12]

    The court issued decisions in 66 cases during its 2021-2022 term. Three cases were decided without argument. Between 2007 and 2021, SCOTUS released opinions in 1,128 cases, averaging 75 cases per year.


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 U.S. Supreme Court, Ruan v. United States (consolidated with Kahn v. United States), decided June 27, 2022
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 U.S. Supreme Court, "Ruan v. United States: PETITION FOR A WRIT OF CERTIORARI," accessed November 8, 2021
    3. ↑ United States Supreme Court, "Kahn v. United States: PETITION FOR A WRIT OF CERTIORARI," accessed November 8, 2021
    4. ↑ 4.0 4.1 4.2 4.3 4.4 4.5 4.6 U.S. Court of Appeals for the 11th Circuit, United States v. Ruan, decided July 10, 2020
    5. ↑ 5.0 5.1 5.2 5.3 5.4 U.S. Court of Appeals for the 10th Circuit, United States v. Khan, decided February 25, 2021
    6. ↑ United States Code, "21 U.S.C. §§ 841(a)(1)," accessed November 8, 2021
    7. ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    8. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued March 1, 2022
    9. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued March 1, 2022
    10. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed February 4, 2021
    11. ↑ Consolidated cases are counted as one case for purposes of this number.
    12. ↑ U.S. Supreme Court, "Order List: 593 U.S.," May 17, 2021
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