Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Not written by a barrister. The name was thought up by a second-year American law student sitting in a coffeehouse in Manhattan. Neither an authoritative statement of the law nor legal advice. Don't rely. Quick work.
Eighth Circuit: United States v. Juan Leanos
Sentencing
Elements of "safety valve" provision allowing for a sentence below the mandatory minimum do not need to be found by the finder of fact.