Ricky P. Wallace argued that he should not have been convicted of cocaine distribution because he merely shared the drug with friends and did not profit from its sale. But the 2nd U.S. Circuit Court of Appeals has informed Wallace that, in some circumstances, sharing can be considered a crime.

In United States v. Wallace, 05-1424-cr, the circuit held for the first time that the “sharing of drugs, without a sale, constitutes illegal distribution for purposes of 21 U.S.C. §841(a).”