Jawayne Watkins v. United States

Whether the Fifth Amendment’s Grand Jury Clause permits a conviction for distributing a specifically charged Schedule I controlled substance to rest on forensic proof that is, by the government’s own account, incapable of distinguishing the charged substance from chemically related isomers that were lawful at the time of the offense.

Whether the “death results” enhancement of 21 U.S.C. § 841(b)(1)(C) is satisfied by expert testimony that death resulted from an unidentified member of an isomer family, only one member of which was a controlled substance.