United States v. Eaton, No. 13-6125 (6th Cir. 2015)
Annotate this CaseInitially charged with eight counts related to excessive force, witness tampering, and obstruction of justice based on his conduct during the 2010 arrest of Stinnett and the subsequent federal investigation, former Barren County Kentucky Sheriff Eaton was convicted of two counts of witness tampering, 18 U.S.C. 1512(b)(3) for instructing two officers to give false statements. The Sixth Circuit affirmed, rejecting claims that the evidence was insufficient to support his conviction; that the court should read a materiality requirement into 18 U.S.C. 1512(b)(3) and should conclude that the statements he procured regarding Stinnett having a knife did not “relat[e] to the commission or possible commission of a Federal offense” under the statute; that the district court erred by failing to instruct the jury on an affirmative defense that the alleged conduct was otherwise lawful and the defendant’s “sole intention was to encourage, induce, or cause the other person to testify truthfully” and erred in failing to give a special unanimity instruction; and that the prosecutor made improper remarks in closing argument regarding Defendant’s failure to testify.
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