the meaning of “results from” is not clear without further explanation. Before the Supreme Court granted certiorari 'and reversed in Burrage, the Eighth Circuit had affirmed the defendant’s conviction in that case, holding that the district court had not erred in instructing the jury that “results from” meant that the controlled substance must have been a “contributing cause” of the death. Id. at 886. Moreover, in a separate opinion in Burrage, Justice Ginsburg, joined by Justice Soto-mayo'r, explained that she would apply the rule of lenity, a doctrine invoked only where statutory language is ambiguous, in interpreting § 841(b)(1)(C)’s text. See id. at 892 (Ginsburg, J., concurring in the judgment); cf. Bifulco v. United States, 447 U.S. 381, 387, 100 S.Ct. 2247, 65 L.Ed.2d 205 (1980) (<HOLDING>). • Thus, even though the Supreme Court has now
holding that the rule of lenity applies to sentencing guidelines holding that the rule of lenity applies only if the provision being construed is still ambiguous after the application of normal rules of construction recognizing that the rule of lenity applies not only to interpretations of the substantive ambit of criminal prohibitions but also to the penalties they impose holding rule of lenity in the penal context to be a rule of last resort recognizing that the rule of lenity applies only after courts exhaust all other evidence of congressional meaning