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August 28, 2016

Some background on drug dealers being criminally responsible for causing overdose deaths (and its possible theoretical justification)

Friday's in-class discussion and debate over the sentecing of (very fictional) Oliwood drug dealer Dan Schayes raised the interesting and controversial (very real) issue of whether persons involved in drug dealing can and should be held criminally liable for the death of a customer.  As the prosecution in the Schayes case noted, federal criminal law already speaks to this issue through a provision in 21 U.S.C. §841(b)(1)(C): it states that a convicted drug dealer involved with serious drug substances generally  "shall be sentenced to a term of imprisonment of not more than 20 years," but that such a drug dealer, "if death or serious bodily injury results from the use of such substance, shall be sentenced to a term of imprisonment of not less than twenty years or more than life."

Toward the end of September, we will looking at the basic substantive criminal law rules that generally apply for determining when and how a defendant can be held responsible for causing a result, and a few years ago this issue in federal law dealing with overdose deaths made it all the way up the US Supreme Court in the case of Burrage v. United States.  I would urge you all NOT to read the Burrage case closely (or at all) at least until we get to our causation discussions in class (though, at that time, you will be able to earn more extra credit for engaging with the Burrage SCOTUS ruling).

On the topic of earning credit, I am now pretty sure I have figured out how to get the comment section of this blog open, and that means every class member can earn some credit ASAP by using the comments here to share thoughts on what theory or theories of punishment might support holding drug dealers criminally liable for the deaths of their customers.  Notably, just a few weeks ago this lengthy and interesting AP article, headlined "Prosecution trend: After fatal OD, dealer charged with death," discussed this kind of criminal action as a growing trend.  And I stirred up some interesting commentary on the trend with this post about that AP article on my main blog titled "Should I be more troubled by drug dealers facing homicide charges after customers' overdose death?"

August 28, 2016 in Class reflections, Current Affairs, Notable real cases | Permalink


After reading the AP article that discusses sentencing drug dealers for murder, it becomes more clear that sentencing these individuals can perhaps create some real change and ultimately save many lives. But the question that arises then is, under what theory should we sentence them? Should we send them to prison because our understanding of justice requires an eye for an eye and ultimately the scales of justice need to be balanced? Or should we sentence them and send them to prison so that in the long run we have safer streets. Perhaps, we should send them to prison so that in future we can rehabilitate them and give them opportunities to rejoin the work force and carry on their lives as citizen of the United states. In my opinion, whether you approach this discussion from a retributivist perspective, or a utilitarian one, one can either succeed or fail depending on how one views those two theories. What I'm trying to say is that its not the title of the theory per say that matters, but its the way that one views that theory and how broad one's understanding is of overarching principles and the details. Its not that retributivism or utilitarianism will give us the answers to our modern ethical dilemmas if applied, but its us who give those words meaning and use their inherent tendencies to reach our desired goals.

A retributivist who thinks that a drug dealers should go to prison solely because they need to repay a debt back to society will most likely create a bigger problem. When the drug dealers eventually leave prison, they will go back to the drug dealing since they have not been given education or at least skills to reengage with society once again. The same retributivist however can be broad minded, and believe that a drug dealer must suffer the pains of justice by serving his or her prison but that also, a drug dealer is a human being. Every human being comes with unalienable rights that no one can take away from him or her. These rights might include education, freedom from substance abuse and the ability to control one's life. This kind of retributivist will most likely ensure that those who do suffer the pains of justice also receive medical help, rehabilitation and also an education.

On the other hand, utilitarianism can be used the same way. A utilitarian might try to find the best long term approach and come to a conclusion that sentencing the drug dealers to years in prison is a great idea because essentially we are incapacitating them. The utilitarian's forward thinking might stop there and ironically create more chaos then good. Essentially, the utilitarian will reach the same results as the justice driven retributivist who can only see prison in the horizon for the drug dealer. By ignoring rehabilitation medical care and education, the utilitarian dams the drug dealer to a life in prison without giving them the skills to reengage with society upon their release.

A truly forward thinking utilitarian will sentence drug dealers in order to rehabilitate them and send them back into the real world so that they may prosper. According to the fiance of Ed Martin who speaks about the time her served in prison, this mentality seems to work. She states:

"He needed jail," she says, noting that he prospered while serving time for fraud. "It made him better, strangely. He was clean. He had a clear conscience. He had the counseling ... He needed to be in there a lot longer than he was."

Jail time seemed to help Mr. Martin by freeing his mind and helping him control his life through counseling. This is the case for millions of Americans who go to prison, they are addicted and cannot get help. Prison can be a safe haven for these dealers and their families if the approach to their sentencing is forward thinking and rights based. We cannot only focus on the rights of the deceased, but must also focus on the rights of the prisoners. After all, our criminal justice system is built on the undisputed facts that even prisoners who commit the most evil of crimes have rights that no one can take away from them.

Posted by: Ali | Aug 28, 2016 5:11:34 PM

I believe that both retributive theory and utilitarian theory could support holding the drug dealer criminally liable for the death of one of their customers. One reason why a retributivist might agree with the punishment is due to the idea of "eye for an eye." The retributive theory believes if someone commits a crime they should have a punishment that equates to the degree their victim had to suffer. So in the case where the victim died, by charging the drug dealer for the death the punishment the dealer will be given as a result would mostly likely have a similar degree of the victims death in the form of time imprisonment.

Those following a more utilitarian approach could also find this punishment justifiable. By finding the drug dealer criminally liable for the customers death this could possibly deter others from the sale and distribution of serious drug substances. If this successfully prevents more crimes like this then it is a punishment that society benefits from. Therefore is justifiable on those terms from a utilitarian view point

Posted by: Ayesha C. | Aug 29, 2016 9:49:38 AM

The above comments offer interesting perspectives on Retributivism and Utilitarianism in their role in supporting holding drug dealers criminally responsible for their clients' overdose deaths, so I would like to pose a secondary question. Could a rehabilitationist approach in these matters do more to limit these drug overdose deaths? I am inclined to say yes, as the stories in the AP article included, at least what seemed to me, to be motivations in these criminal conducts related to drug addiction. I am curious as to what others think the ramifications of such an approach would be.

Posted by: Alex S. | Aug 29, 2016 3:46:20 PM

I am of the mind that using these draconian methods to punish drug dealers does not serve any legitimate penological goal historically accepting by the Supreme Court.

In terms of retributivism, it seems to me that giving a drug dealer just because someone else ODed removes responsibility from the person that chose to injest the drugs. This dynamic takes on a special irony when the overdose victim 1) would otherwise be a societal outcast and "deserving" of being locked up on a possession charge OR 2) the victim could never possibly be blamed for injesting drugs because they were of more "upstanding" stock.

I chuckle when people use deterrence as an argument for drug prohibition, especially when the market for drugs remains so socioeconomically diverse.

As for incapacitation, locking up a few overdose drug dealers may incapacitate those individials in the definitional sense, but does very little to incapacitate the drug market itself. Even locking up the kingpins hasn't been very effective (anyone else watch Narcos? El Chapo is still in prison, too isn't he?). Furthermore, there's some academic research that shows that so long as the demand persists, prohibition actually creates incentives for participation in the drug market for suppliers. There's a recent Harper's Weekly article on this topic.

Finally, I tend to think our correctional systems do an inadequate job of rehabilitating drug offenders, both users and sellers. I also believe that rehabilitation is best accomplished in a non-prison setting (see references to the HOPE model in the textbook). When I hear legislators refer to the expense of prison and the system itself as "crime school" and in the same breath advocate for continuing the War on Drugs with longer penalties for possession and low-level trafficking crimes, I want to scream.

As is probably apparent by now, I am a strong proponent of the public health approach to drug treatment, as opposed to the criminal justice approach we've been using since the Nixon administration. I don't think big-picture, long term the pursuit of "locking up the dealers" will yield much more than more mass incarceration at the expense of taxpayers. To respond to Alex S.'s question, I am of the mind that the rehabilitation approach works best, but away from the criminal justice setting.

Posted by: David R. | Aug 30, 2016 5:11:46 PM

I fail to see, as David has described in detail, how any utilitarian goals could be achieved by holding a drug dealer responsible for the overdose deaths of their costumers. The debate of whether utilitarian goals are successful in sending a dealer to prison has already been explored. I think, however, that the intent behind holding dealers responsible for the overdoses resulting from the drugs they sell is not an attempt to lock up more dealers for longer periods of time, but to lower the number of overdoses.

If the overdoses were the result of intentional or negligent overuse of a drug by the customer, I think we could not hold the dealer responsible. Doing so would be analogous to holding a gun salesman responsible for his unknowingly selling a gun to a suicidal or careless man. Rather, I believe what is going on involves the mix of the drug. To my knowledge, which is almost nonexistent on this subject, overdoses are often associated with users unknowingly buying a more potent mix (the drug mixed with other drugs or substances). This theory correspondence with AP's quote of New Hampshire Attorney General Joseph Foster saying, ""We need to send that message that you can't sell things that are the functional equivalent of poison[]."

If it is true that the main issue is the quality of durg being sold, the only possible utilitarian penological justification that comes to mind is deterrence. However, the punishment would not deter dealers from selling. At best it would only deter dealers from selling questionable mixes of drugs. Considering that the dealer is often not the party who mixes the drug, even this effect would be minimal.

Posted by: Joshua M. | Aug 30, 2016 8:50:12 PM

I think that a good way to consider how this article relates to the different theories of punishment is to consider quotes from both the PD and the Prosecutor in the case...

PD Hornick:"I find it so counterproductive that they think sending these people to prison for long periods of time is going to have any deterrent effect. It's an easy fix and perhaps it satisfies part of the population. In reality, they come out and don't have the tools or skills to return to society."

This is of course the standard utilitarian-type argument which maintains that (often draconian) retributive punishments are counter-productive and expensive. I tend to agree with this general sentiment, as well as David's and Alex's, that forward-looking rehabilitation is probably the best way to deal with drug crimes.

Still, I don't think it's necessarily bad or unjust that drug dealers be held criminally liable for deaths (at least the "but-for" variety of death) I just think it probably ought to entail less jail time and instead result in rehabilitative or restorative treatment.

What typically enrages me, however, are comments on the other end of the theory-of-punishment spectrum like the one from Prosecutor Vara in the article:

"But Vara... rejects suggestions this is a politically motivated plan without merit. 'Say that to a family who lost their child, their son, their brother, their daughter,' he says. 'Say that to Ed Martin's two children who are without their father as a result of this.'

I find this comment to be completely irrelevant and hypocritical and just generally shitty.

First I would like to say that, had the police picked up Ed Martin for using heroin a day before he OD'd, I suspect strongly that when it came time to prosecute him Vara wouldn't see Martin as a "father". He would see a criminal that needed to go to jail.

That argument notwithstanding, I hate that Vara assumes that everyone who loses a loved one from a drug overdose blames the drug dealer. Even if that is true (it isn't) how does prosecuting the dealer help the family? Closure? Satisfaction that justice has been done? I just don't buy it at all.

I think all of this gets at two things that I've taken away from all of our discussion about theories of punishment:
1) Pretending that the choices are between only retributivism and utilitarianism is not particularly helpful. There are a billion different takes on these theories and, even though most of them may have the words "retributive" or "utilitarian" in their titles we quickly approach a point in these discussions where it'd be helpful to have different words to use.

2) I think a given person's feelings on the different theories of justice depend a lot on the particular type of offense. I think the ball has moved a lot towards utilitarianism when it comes to drug users (although I have a LOT of thoughts about why we didn't see Chris Christie - or other leaders - crying about all the people whose lives were irrevocably harmed in the 1980s, 90s or 00s by other drugs) BUT it hasn't moved so far when it comes to questions about the death penalty or sex workers or a large variety of other offenses.

What I'm trying to get at here is that it might not really make sense to describe any one person as a retritubtivist or utilitarian or any one strain of thought, because we probably all hold internally inconsistent values about punishment depending on our perceptions of different crimes.

Sorry that was so long.

Posted by: Joe Barton | Aug 30, 2016 8:56:24 PM

Last night I was up watching a documentary on the History Channel that really got me to re-examine this question. The doc was filmed inside Albany county correctional facility, one of the worst prisons in the state of New York. It followed a series of prisoners who had varied offenses, ranking from petty marijuana dealers to convicted murderers. At one point, the documentary examined the lives of many inmates who had ended up in prison due to their heroine addiction. One young man had found him self in prison after a heroine high in which he killed an innocent hairstylist and stole cash from the salons register in order to feed his addiction. Another was a mother of 4, who started heroine when she was 35 and within 4 years, lost everything including her freedom, her children and her job. They all tell interesting tales about the role drugs played in their lives.

At one point, the documentary focused on heroine, and its negative consequences. About 70 percent of inmates that had frequented the prison had been caught with heroine or had been high at the time of arrest. When these prisoners are admitted into the facility, they aren't given medical treatment to help with their withdrawals, rather they are placed in cells where they have to go through their withdrawals on their own, cold turkey as well call it, until their body detoxes. For many prisoners this is hell. Some commit suicide because they can't take the sheer agony of withdrawal, others force themselves through it. One women who was convicted to 4 years in prison wakes up one day to find her daughter in the cell next to her, going through heroine withdrawals. She sits out side of her daughters cell crying while her 19 year old daughter goes through the agony of heroine withdrawals.

It's at this point that she makes an argument for the benefits prison can have on drug addicts. If it was not for prison she claims, she would never have controlled her drug addiction nor would she have had any incentive to do so. For her, prison seems to be the force that got her to go clean and look at what really mattered in her life. We see the same thing being stated in the AP article about Mr. martins and the time he spent in prison. With that being said, for every person who is in prison because they actually want to get better as they usually do, there are 1000 others waiting to get out in order to indulge into their heroine habits once again. This was the story of one young man, who finished his prison sentence, but found himself right back in the slammer after making $10,000 from dealing heroine.

I'm now rethinking this question because if we're going to convict drug dealers and simply send them to prison to rot in their withdrawals and give them no medical care of any other sort in the rehabilitative process (which is literally what is going to happen), then its a waste of our money and our resources and also a terrible way to treat a human being who genuinely has problems.. At the end of the documentary, one officer who was in charge of the daily routines gives a very insightful comment. He stated as he spoke to the camera about the hell these prisoners go through that in reality, the prison serves one main purpose: to protect society from people who can be a danger to its stability. This was in my opinion the most honest answer given by a someone who see's the daily reality of a correctional facility. Prison seems to be nothing more then a cage were we keep the baddest and most dangerous people because we don't want the rest of society to be affected by their mischief. Ideally this is one of the goals behind convicting criminals, but now, it has become the ultimate goal and the driving force of our ever growing prison system. I don't want to be naive here, of course many of these criminals deserve to be in prison for a very very long time because of the crimes they have committed towards society, but in the context of drug addiction and drug abuse, I don't think it warrants the same approach. Our prison system just docent have the capacity at the moment for the "ideal" rehabilitative structure that we are looking for and demanding. At most we will get forceful withdrawals which is the lowest form of rehabilitation and nothing more.

Posted by: Ali N. | Sep 1, 2016 10:52:26 AM

The article states that punishing these dealers with a homicide or involuntary manslaughter is a good way to deter drug dealers and deliver justice.

I am very conflicted with my opinion on whether a drug dealer should be held liable. In one comment I read on Professor Berman's post, a man stated that a drug dealer is not a doctor and cannot predict who is going to OD and die from the drug. However, I think that could be true of many crimes and arguing that a person couldn't predict that it wasn't going to happen is not fair defense. Just because the drug dealer did not have the intent to kill whoever he gives the drug to, does not mean he should be relieved of liability.

A utilitarian would argue that it is better and safer for society to incapacitate and punish a drug dealer The problem with the utilitarian idea of incapacitating the drug dealer so they are not in the streets able to sell is that drug dealers are replaced very easily. So essentially a punishment only affects the individual and not the team of drug dealers. So as we imprison one, a new drug dealer takes over and essentially society is left with the same problem. Another utilitarian approach that might be better is the idea that there punishment consists of rehabilitation. Maybe this means giving them the means or education to find a different job when they leave prison. The time served and sitting in jail could be the necessary component to get a drug dealers life straight. One woman said that jail helped, not only be clean from drugs, but also clears one's conscience. Or he could leave jail and return to drug dealing and essentially nothing will have changed. However, on the theory

A retributivist would argue that the drug dealer needs to be punished for the crime. Further, one could argue that since his drug killed an individual, he needs to be punished for that death since that would equal the degree that the victim suffered. It also goes along with the concept that someone has to pay for the death or be held responsible.

I am not sure where I stand, but as bad as jail sounds, I think it can be a great rehabilitation place for some criminals. I emphasize some because I am sure bad stuff happens in jail and not everyone goes in and tries to come out better. But for some people, it can be a place where they can serve the punishment for their crime (retributivist) but also learn how to come out and be a better asset of society (utilitarian). We have constructed a criminal system based on justice and therefore, I think it is important to think about the rights of the prisoners and what will best help and appropriately punish them. I do agree that there has to be some level of responsibility for the drugs they sell and then death that results, but I find it hard to pin a murder charge on them. There has to be some level of responsibility on the person who died who chose to buy and use that drug, that was not forced upon them. It's easier to find someone else to blame and pin the crime on, but I do not agree with charging the dealer with the murder.

Posted by: Sophie D. | Sep 1, 2016 6:17:29 PM

The transactional history which exist between a drug dealer and their client is a complex process which possesses many legal and theoretical questions. From a practical legal perspective, drug dealers should be held responsible for whatever calamity ensues from their illegal business. They are supplying controlled substances to the community which is the very premise for which we rational that drug dealing should be illegal. However, there is debate over whether criminalizing the act of drug dealing, in and of itself, is sufficient to ensure the future safety of the public. After all, the purpose of the law and its' enforcers is to protect and serve the community for which these laws have been created. In this response, I hope to touch on a few topics which would unravel the layers of complexity which shroud this strange concept of drug dealing and the ramifications this activity has on those who are on the receiving end of the business.

Drug dealing is illegal because it supplies the individual or community with substances which have been deemed illegal. Thus, we seek to condemn drug dealers because they are more detrimental to society than the average drug user which is utilitarian in nature. Often times, drug dealers will create business oriented relationships with individuals who seek to supply a particular area with drugs. These relationships are inherently secretive and the identity of the “whole sale” supplier, whom the drug dealer acquires his stock from, is not widely known throughout the community. Furthermore, the relationship between the drug dealer and whole sale provider is inherently exclusive which often times implies that this relationship manifest itself through some other means such as gang or cartel relations. Thus, it is not farfetched to believe that drug dealers not only supply their local geographical area with illegal substances, but that they also create the incentives for more dangerous and expansive entities to remain in their proximity.

Taking all these factors into account, as a society, we generally charge the drug dealer as being more responsible than the drug user. This perspective is clearly utilitarian because it seeks to punish the drug dealer for the broader impact of his actions with the intent to rid the community of his heinous crimes. However, there are multiple dimensions which come into play when the transaction between a drug dealer and a drug user results in death by overdose. In this situation, the blame and culpability of both parties is not so clear cut. Rather, it is difficult to discern whether or not the drug dealer or user is more to blame for the transaction which resulted in the inadvertent death.

In recent years, America has started a trend which has addressed whether or not drug dealers should be responsible for the drug related deaths of their customers. Furthermore, in many of these cases, there is evidence that the contemporary American judicial system finds the drug dealers to be responsible for the deaths of their patrons. In my opinion, this trend is purely utilitarian in its intent. In addition, the stark difference in holding the drug dealer responsible for the deaths of his patrons as opposed to the act of originally providing the drugs to that aforementioned patron solidifies the utilitarian nature of this trend.

Taking all these variables into account, the drug dealer was guilty of one crime only, the crime of providing drugs to the drug user. In my opinion, from a retributivist point of view, the drug dealer is only held responsible for the criminal acts which they engaged in. The act of overdosing on illegal drugs is a burden which is solely meant to be carried by the drug user. For the sake of analogous example, think of the pharmaceutical companies. Pharmaceutical companies provide legal drugs to the public which often times runs the risk of causing serious bodily harm or even death if misused. However, it is often times the patron’s responsibility to be aware of these harmful possibilities. In using the drug, they understand that if they misuse it, it could potential cause them serious harm. Thus, the same standard is applied to the drug dealer and his patron. In purchasing the illegal drugs, the patron assumes the risk which comes with their use. Thus, we see a shift in blame from the drug dealer to the drug user. However, the punishment of the drug dealer for the overdose of the patron is still warranted because it creates a common good for the public.

Applying utilitarian concepts to the punishment of drug dealers serves a deterring effect which in turn serves the future good of the community. Making the drug dealer somewhat responsible for the compounded illegal behavior which inadvertently led to death by overdoes is a way of ensuring that drug dealers know the high stakes at play when engaging in their illegal business. Thus, I believe this trend’s deterrence capability makes it more utilitarian in its intent as opposed to retributivist.

Posted by: Matthew Carpenter | Sep 1, 2016 10:53:12 PM

Both retributive and utilitarianism theory would be able to support the law as many of you mentioned in the comment. I believe utilitarianism explains it better though.

I agree with Sophie that "a utilitarian would argue that it is better and safer for society to incapacitate and punish a drug dealer." If the sole purpose of regulating drug is to punish use of drug, it is enough to punish users. Sellers are creating danger in the society, make it possible for people to use it, and make money from it. Retributivist can say that drug dealers deserves punishment for the reasons above, but just selling drug does not harm society if nobody use or buy it. Regulating distribution of harmful things are future-focused approach, and punishment of drug dealers is not exception.

When people use drug, it is foreseeable for the users that the drug may cause serious health and mental problem or even death. So if we see it only from retributive perspective, the users may deserve death, and the person who are responsible for that is the users, who knowingly and recklessly use illegal drug. To justify extra punishment for the death of user to drug dealers, I think utilitarianism theory suits better. by distributing drug, the dealers have possibility to kill buyers, and extra punishment may prevent them from selling it. Some people would think the money they earn from drug dealing pays more than a few years imprisonment, but presumably, fewer people think the money is better than life sentence. So the future-focused approach can justify this sentence.

I am, however, skeptical for the effectiveness of the law. It is not very realistic to prove the drug caused death of person. As defense side mentioned in their presentation, a lot of drugs could be manufactured in same place, and furthermore, it is possible that some people resell the drug. Although I am skeptical, I still think it is worth having this law to incarcerate high risk dealer longer than 20 years.

Posted by: Miki Someya | Sep 3, 2016 11:04:44 PM

While reading the AP article, it was eerily interesting to see the similarities of the postcard descriptive feeling of Littletown, New Hampshire to suburbia Southwest Ohio.

The heroin epidemic has become such an intense topic of conversation in Cincinnati and throughout the state. Only a few days after our first class trial presentation, my mom called to tell me that their favorite waitress at our local sports bar passed away from a heroin overdose. It was startlingly to hear but even more startlingly in how I am no longer surprised to hear those personal stories.

With the heroin epidemic and our criminal justice system, I agree with David in the importance of looking at this through more of a public health lens outside of incarceration – looking at these individuals suffering and plagued with addiction as human beings who need treatment. Instead of investing such a substantial percentage of tax dollars into incarceration, I believe it is beneficial to invest and continue to look into treatment and rehabilitative programs different from simply putting individuals behind bars. A part of me feels much more comfortable looking at this through a utilitarian view of punishment, especially after reading the AP story.

The issue I truly grapple with is when the dealer is not portrayed in a sympathetic manner such as Mike Millette in the AP article. What happens when the dealer is not an addict, but rather more of a perceived “entrepreneur praying on the addiction of others?” In theory, I am not one for retribution, but I cannot imagine losing a family member to an addiction fed by an individual such as El Chapo or Oilwood’s Dan Schayes and a product laced with fentanyl.

I lose my deep gut feeling of sympathy and my initial inclination towards a utilitarian view of punishment when I think of drug dealing as a business. My gut has a difficult time full-heartedly arguing against retributive punishments when the dealer was selling on such a grand scale or just because they wanted extra money to buy something as trivial as an Xbox or fund a more grandiose lifestyle.

I would like to think we would have more a utilitarian mentality with handling the heroin epidemic - looking to finding a punishment system that better ensures less overdoses and lost life - but I can understand what the prosecutor is saying in the article. I believe in forgiveness and moving forward together – but as the prosecutor said: “Say that to Ed Martin’s two children who are without their father as a result of this.” I would not judge a family member or prosecutor for wanting an eye for an eye. But I know how debilitating relying on perception and portrayal can be in pursuing justice. We can never really know an El Chapo from a Mike Millette.

I apologize if any of this is offensive or uninformed. I am only saying this from my personal experience and trying to grapple with how to effectively confront the heroin epidemic. Even saying that I know is uninformed. Over the years, heroin has been a pervasive problem. It feels wrong to just now have such a broad interest and investment in time to confront this issue. It just does not seem that suburbia Ohio has any idea what to do with the heroin epidemic in general, myself included. As Mike Millette said in the end of the article, “I don't know what's going to work with this epidemic. I really don't."

Posted by: Maggie O'Shea | Sep 6, 2016 3:29:04 PM

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