United States v. Christopher Eaton
784 F.3d 298
| 6th Cir. | 2015Background
- Sheriff Christopher Eaton and deputies arrested Billy Stinnett after a car chase; Stinnett testified Eaton and deputies used significant force, including baton strikes, while Stinnett attempted to surrender.
- The FBI investigated after civilian witnesses reported the incident; Agent Brown requested use-of-force reports from Eaton and his deputies.
- Deputies Adam Minor and Steve Runyon later testified that Eaton instructed them to prepare false reports (including a story that Stinnett pulled a knife and resisted) and pressured them to transmit those reports to the FBI.
- Runyon and Minor said they complied out of fear of losing their jobs; both admitted prior inconsistent statements and, in Runyon’s case, false grand jury testimony.
- A jury acquitted other deputies and acquitted Eaton on excessive-force counts but convicted Eaton on two counts of witness tampering under 18 U.S.C. § 1512(b)(3); Eaton appealed.
Issues
| Issue | Plaintiff's Argument (Government) | Defendant's Argument (Eaton) | Held |
|---|---|---|---|
| Sufficiency / materiality under §1512(b)(3) | Evidence shows Eaton corruptly persuaded deputies to create false reports about facts (knife/resistance) relating to the federal investigation | §1512(b)(3) should be read to require that the suppressed information be material to the federal offense; knife evidence not material to alleged excessive force after handcuffing | Conviction affirmed; court rejects adding a heightened materiality requirement — information “relates to” the possible federal offense if it concerns the incident under investigation. |
| §1512(e) affirmative defense (solely lawful conduct to induce truthful testimony) | No defense evidence; jury instructions on elements sufficed | Court should have instructed jury sua sponte on §1512(e) defense | No plain-error; defendant failed to present evidence supporting the defense, so omission not reversible. |
| Special unanimity instruction for Count 5 (duplicitous theory: conceal force vs. false knife claim) | N/A (prosecution argued both theories fall under "information") | Failure to require jury unanimity as to which factual basis (force details vs. knife) deprived Eaton of unanimous verdict | No plain-error; differences are "brute facts" within a single element (information), unanimity instruction not required. |
| Prosecutorial misconduct (closing remarks implying Eaton’s silence) & cumulative error | Remarks were about defendants’ written reports, not testimonial silence; any error was harmless given strong evidence and curative instructions | Prosecutor’s rebuttal improperly commented on Eaton’s failure to testify; cumulatively errors mandate reversal | No reversal; any implication of comment on silence was mitigated, not flagrant, and cumulative-error claim fails. |
Key Cases Cited
- United States v. Jones, 102 F.3d 804 (6th Cir. 1996) (standard for Rule 29 sufficiency review)
- United States v. Mathis, 738 F.3d 719 (6th Cir. 2013) (court will not reweigh evidence or reassess witness credibility on sufficiency review)
- United States v. Carson, 560 F.3d 566 (6th Cir. 2009) (§1512(b)(3) does not require nexus to a particular federal investigation; purpose is protecting integrity of federal investigations)
- Richardson v. United States, 526 U.S. 813 (1999) (distinguishes elements from means/brute facts for unanimity requirements)
- Arthur Andersen LLP v. United States, 544 U.S. 696 (2005) (discussed by parties regarding materiality but addressed different mens rea context)
- Smith v. United States, 133 S. Ct. 714 (2013) (defendant may support an affirmative defense by producing evidence or directing court to substantiating evidence)
- United States v. Kakos, 483 F.3d 441 (6th Cir. 2007) (plain-error review for failure to give special unanimity instruction)
- United States v. DeJohn, 368 F.3d 533 (6th Cir. 2004) (applying Richardson to multi-means charges)
- United States v. Schmeltz, 667 F.3d 685 (6th Cir. 2011) (multiple false statements in a document treated as a single falsification; no duplicity concern)