Professor Spenser has another blog, Split Circuits. Of note, he states that in U.S. v. Medina, --- F.3d ----, 2005 WL 2740828 (1st Cir. Oct. 25, 2005).
The question whether the statute regulates only possession of crack or whether its rule encompasses other forms of cocaine base is the subject of some debate and of a conflict among the circuits. See, e.g., United States v. Edwards, 397 F.3d 570, 575-77 (7th Cir.2005) (describing split). In this circuit, however, it is settled that 21 U.S.C. § 841 regulates exactly what its terms suggest: the possession of any form of "cocaine base.
I didn’t put this in my post on the coverage here, so you might want to revisit it.
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