7th Cir.

United States v. Corruthers

April 27, 2026 ·24-2489 ·Panel Decision ·Pryor · By James Taylor

The Seventh Circuit affirmed an above-guidelines sentence for a defendant who facilitated a straw purchase of a firearm that was later used to kill a police officer. The court held that the district court acted within its discretion to vary from the Sentencing Guidelines based on the unique circumstances and consequences of the offense.

Background

Ashantae Corruthers agreed to purchase a firearm for a third party, Darrion Lafayette, who then used the weapon to fatally shoot Officer Oberheim and wound Officer Creel during a police-involved shooting. Corruthers later provided false statements to federal agents regarding the transaction. She was convicted of conspiracy to illegally purchase a firearm and conspiracy to engage in misleading conduct. The district court sentenced her to forty-eight months, an above-guidelines term, citing the severe consequences of her actions and a policy disagreement with the Guidelines’ treatment of straw purchasers.

The court’s reasoning

The Seventh Circuit reviewed the sentence for substantive reasonableness under the factors set forth in Section thirty-five fifty-three of Title eighteen of the United States Code. The court found the district court adequately justified the variance by noting the non-routine nature of the straw purchase and the resulting violence. Regarding the government’s cross-appeal, the court held that the district court did not clearly err in declining to apply the obstruction of justice cross-reference because the underlying investigation focused on police corruption rather than a murder inquiry.

In this case, I cannot ignore the manner in which this gun was provided to a violent felon, and Ms. Corruthers met Mr. Lafayette.

District Court Dkt. 89, at 16

What it means going forward

The decision reinforces the discretion of district courts to impose above-guidelines sentences for straw purchases when the specific circumstances involve severe consequences, while limiting the application of obstruction cross-references to investigations explicitly focused on the underlying crime.