In 2013, United States Attorney General Eric H. Holder, Jr. announced that the Justice Department would follow a new policy restricting mandatory minimum sentences in certain drug cases. Prosecutions dropped, drug enforcement agent morale dropped, and fentanyl and heroin overdoses soared, reported The Washington Post in 2019. In Alleyne v. United States (2013) the Supreme Court held that increasing a sentence past the mandatory minimum requirement must be submitted by a jury and found factual beyond a reasonable doubt. It increases the burden on the prosecutor to prove that the sentence is necessary for the individual crime by requiring that a mandatory minimum sentence be denied for defendant unless they fulfill certain criteria. Attorney General Holder held that the charges placed on an individual should reflect the uniqueness of the case and consideration in assessing and fairly representing his/her given conduct. This is supposed to prevent recidivism.