United States v. Eaton

The federal government (plaintiff) prosecuted county sheriff Christopher Eaton (defendant) on two counts of witness tampering, in violation of 18 U.S.C. § 1512(b)(3). That statute prohibited tampering with the reporting of a federal offense. The trial evidence established that Eaton and several of his deputies severely beat Billy Randall Stinnett, whom they had just arrested and handcuffed after a high-speed chase. The excessive use of force against a handcuffed prisoner was a federal offense. News of the incident eventually reached the Federal Bureau of Investigation (FBI), which launched an investigation and ordered Eaton and his deputies to prepare reports of what happened before, during, and after Stinnett's arrest. Deputies Adam Minor and Steve Runyon testified that Eaton forced them to report, falsely, that Stinnett had resisted arrest and pulled a knife on Eaton. Eaton reviewed both reports and added embellishing details to Minor's report before sending the reports to the FBI. Eaton subsequently used his power over Minor and Runyon to try, unsuccessfully, to prevent them from later changing their stories. The jury convicted Eaton on both counts, and he appealed to the Sixth Circuit Court of Appeals. Eaton contended that the testimony of two admitted perjurers, who over time changed their accounts of the Stinnett incident, could not support the jury's convictions. Eaton also contended that, because the false incident reports related to Stinnett's conduct before his arrest, and the federal offense under FBI investigation took place only after Stinnett was handcuffed, any false statements in the deputies' reports did not materially relate to the commission of a federal offense.