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.