United States v. Rash

Oscar Rash (defendant), a felon charged with unlawful firearm possession, conceded at trial that he had the gun but falsely claimed he was merely returning it to his girlfriend rather than helping her buy it, even though the gun store's surveillance video showed him assisting with the purchase. He was convicted and given a since-invalidated mandatory minimum sentence; at resentencing, the judge applied a sentencing enhancement under U.S.S.G. § 3C1.1 for obstruction of justice based on his 2007 false testimony, and Rash appealed, arguing his lie wasn't material since he'd already admitted possessing the gun.