Burrage v. United States, 571 U.S. 204 (2014), was a United States Supreme Court case in which a unanimous Court held that a defendant cannot be liable for penalty enhancement under the penalty enhancement provision of the Controlled Substances Act unless such use is a but-for cause of the death or injury, at least when the use of a drug distributed by the defendant is not an independently sufficient cause of the victim's death or serious bodily injury.

When police searched their home and vehicle, they found syringes, 0.59 grams of heroin, alprazolam and clonazepam tablets, oxycodone pills, a bottle of hydrocodone, and other drugs.

The district court also declined giving Burrage's proposed jury instructions, including requiring the government to prove that heroin use "was the proximate cause of [Banka’s] death."

Because the deceased in this case was found with multiple drugs in his system, the heroin sold by the defendant could not be considered an independently sufficient cause of death.

Citing her dissent in University of Texas Southwestern Medical Center v. Nassar, 570 U.S. 338 (2013), she argued that the Court's interpretation of similar language (in that case, "because of") lacked sensitivity to real-life concerns.