In the 1992 case of Sandra Jean Smith v. United States, the U.S Supreme Court ruled on whether a federal law that imposed mandatory minimum sentences for drug offenses was constitutional when applied to a defendant who had not been informed about it during plea negotiations. The court held in favor of the government, ruling that there is no constitutional requirement for prosecutors to inform defendants about such laws before they enter into plea agreements. This decision upheld Smith's five-year prison sentence for her role in a cocaine distribution conspiracy despite her claim that she would have negotiated differently or gone to trial if she had known about the potential mandatory minimum sentence.

In the dissenting opinion for Sandra Jean Smith v. United States, Justice Blackmun argued that the majority's interpretation of "use" in 18 U.S.C §924(c)(1) was too broad and inconsistent with Congress' intent. He contended that a firearm must play an active role in a crime to be considered as being used during or in relation to any crime of violence or drug trafficking crime. In this case, he believed that merely trading a gun for drugs did not constitute "using" it within the meaning of the statute because it didn't facilitate or actively participate in committing another offense such as threatening, brandishing, firing, striking with, etc., which are more consistent with ordinary understanding of 'use'. Therefore according to him convicting Ms. Smith under this law was inappropriate since she only bartered her firearm but never employed it offensively against anyone.