United States v. Eaton

Sheriff Christopher Eaton (defendant) and his deputies severely beat a handcuffed arrestee, Billy Randall Stinnett, a federal offense that drew an FBI investigation. Eaton pressured deputies Minor and Runyon to falsely report that Stinnett had resisted arrest and drawn a knife, personally reviewed and embellished Minor's report before sending both to the FBI, and later tried unsuccessfully to stop the deputies from correcting their accounts. Eaton was convicted on two counts of witness tampering under 18 U.S.C. § 1512(b)(3) and appealed, arguing the perjuring deputies' shifting stories could not support conviction and that the false statements, describing pre-handcuffing conduct, were not material to the federal offense (which occurred only after handcuffing).