Background
Ashantae Corruthers conspired to purchase a firearm for a third party, Darrion Lafayette, who used the weapon to fatally shoot a police officer during a domestic dispute. Corruthers pled guilty to conspiracy to illegally purchase and transfer a firearm and conspiracy to engage in misleading conduct. The district court sentenced her to forty-eight months imprisonment, an above-guidelines term, citing the non-routine nature of the straw purchase and the resulting violence.
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 explaining that the standard guideline did not account for the consequences of violence committed by others. Regarding the government’s cross-appeal, the court held 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 investigation.
In this case, I cannot ignore the manner in which this gun was provided to a violent felon, and Ms. Corruthers met Mr. Lafayette. I might not feel the same way if Ms. Lewis, the codefendant, had simply gone to Corruthers, got the gun, taken the gun back to Lafayette, and given it to him. But in this case, Lafayette was someone who she met. She encountered. I presume there were discussions with Mr. Lafayette. They didn’t just sit there silently together. It is not a routine straw purchase type of case.
United States v. Corruthers, No. 24-2672 (7th Cir. 2026)
What it means going forward
The decision reinforces the ability of district courts to impose above-guidelines sentences for straw purchases when the specific facts demonstrate a heightened risk of violence, while clarifying that obstruction enhancements require a factual basis that the underlying investigation was for a specific crime like murder.