Initiating Meth Production in Tennessee Is a Serious Drug Offense

Following its in United States v. Eason, 919 F.3d 385 (6th Cir. 2019), which held that the Tennessee offense of promoting meth manufacture is a serious drug offense under the Armed Career Criminal Act, the Sixth Circuit held that the related Tennessee offense of initiating meth production was also an ACCA drug predicate in United States v. Myers.

Essentially, the Sixth Circuit concluded that the same reasoning employed in Eason applied. The defendant argued that using thousands of commonplace chemicals - also used in meth manufacture - would violate the statute. But the Sixth Circuit again returned to Eason, explaining that if purchasing a meth ingredient with reckless disregard for its intended use involves the manufacture of meth, then knowingly initiating a process intended to manufacture meth "surely involves its manufacture as well." The statutes "knowingly" language lent further support to this conclusion.