United States v. Gary Eugene Straach

987 F.2d 232, 1993 U.S. App. LEXIS 5059, 1993 WL 76359
CourtCourt of Appeals for the Fifth Circuit
DecidedMarch 19, 1993
Docket91-1355
StatusPublished
Cited by57 cases

This text of 987 F.2d 232 (United States v. Gary Eugene Straach) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Gary Eugene Straach, 987 F.2d 232, 1993 U.S. App. LEXIS 5059, 1993 WL 76359 (5th Cir. 1993).

Opinion

GOLDBERG, Circuit Judge:

Defendant Gary Eugene Straach is a licensed firearms dealer who owns and operates Shooting Sports, a gun shop in Dallas, Texas. After a lengthy “sting” operation carried out by the government, Straach was indicted and later convicted of knowingly selling firearms to nonresidents by way of “strawman transactions.” A straw-man transaction is one in which a resident of the state in which the firearms dealer’s business is located acts as an intermediary or agent for a nonresident who wishes to purchase a gun. With few exceptions, such transactions are prohibited by the Gun Control Act of 1968,18 U.S.C. § 921 et seq. 1 The government contends that not *234 only was Straach aware that he was selling firearms to Texas residents acting as agents for nonresidents, Straach was also aware that the nonresidents were drug dealers who would use the firearms to commit violent acts.

Straach was indicted and tried on five counts, each of which charged that he acted as a principal and that he aided and abetted his employees Pischer and Hogue. Counts two through five pertained to the substantive offenses of willful sales of firearms to nonresidents; while count one pertained to conspiracy to sell firearms to nonresidents, with knowledge or a reasonable belief that the firearms would be used to commit drug-related violent crime. 2 A jury convicted Straach on counts two and five, and acquitted him on counts one, three and four. Straach was fined $100 and sentenced to one year in prison, to be followed by three years supervised release.

On appeal, defendant contends that the evidence was insufficient to support the jury's verdict on counts two and five; that the jury’s verdict of acquittal on count three bars his conviction on count two; that the court erred in refusing to declare a mistrial due to jury misconduct; and that the court erred in instructing the jury to continue deliberations after the jury indicated that it had reached a verdict on counts two through five, but was unable to reach a verdict on count one. Straach seeks acquittal or a new trial. Our jurisdiction is predicated upon 28 U.S.C. § 1291. Finding no error, we affirm the defendant’s conviction.

FACTS

After several Jamaican drug traffickers were apprehended in 1987 .and 1988 and found to possess guns purchased from Shooting Sports, the Bureau of Alcohol, Tobacco and Firearms of the United States Department of the Treasury (“BATF") undertook an undercover investigation of Straach. Prior to beginning their undercover investigation, representatives of various law enforcement agencies visited Straach at Shooting Sports, to ascertain that Straach understood what the law required of him and to ask Straach to report license plate numbers of vehicles owned by buyers about whom he was suspicious. These law enforcement officers claim they gave Straach a BATF circular which defined the term “strawman transaction” and stated that strawman transactions are illegal.

Straach was indicted in 1990 and tried on five counts involving conspiracy and willful sales of firearms to nonresidents by way of strawman transactions, in some cases with knowledge or reason to believe that the firearms would be used to commit violent acts in furtherance of the trade in illegal drugs. Straach pled “not guilty” to all counts.

At trial, evidence of the strawman sales listed in counts two through five was provided by audiotapes of the transactions. These transactions involved a nonresident undercover law enforcement officer (Albrit-ton), accompanied by a Texas resident *235 (Bishop) who filled out the necessary paperwork and displayed a Texas driver’s license. Straach claims he was not present during crucial parts of the transactions that were taped, but the government presented witnesses who testified that Straach was present during the transactions. Evidence of strawman transactions predating the undercover operation was presented by witnesses, including Straach’s employees, Hogue and Pischer. 3

The audiotapes and witnesses both demonstrated that nonresidents came to Shooting Sports with Texas residents in order to purchase firearms, and that in at least some instances the nonresidents openly discussed their domiciles while in the shop. Although the Texas residents showed their drivers’ licenses and filled out the necessary paperwork, the nonresidents selected the guns to be purchased, asked all or most of the questions about the guns, and negotiated prices.

Straach made his customers complete BATF Form 4473 (“Firearms Transaction Record”), which Straach usually filed with BATF as required. Form 4473 contains the following caution to sellers and buyers alike:

WARNING — The sale or delivery of a firearm by a licensee to an eligible purchaser who is acting as an agent, intermediary or “straw purchaser” for someone whom the licensee knows or has reasonable cause to believe is ineligible to purchase a firearm directly, may result in a violation of the Federal firearm laws. 4

On August 4, 1988, Albritton, a nonresident BATF agent, entered Shooting Sports accompanied by Bishop, a resident law enforcement agent. Neither Albritton nor Bishop disclosed that they were law enforcement agents. Bishop asked no questions and did not examine any of the firearms. Albritton asked Straach questions about the firearms available for purchase in the store, and after looking at several firearms, said he was interested in buying three guns. Straach told Hogue to continue handling the sale. Hogue asked Albrit-ton for his driver’s license, and Albritton indicated that Bishop would complete the necessary paperwork. Bishop completed Form 4473 and displayed his Texas driver’s license. Straach told Bishop which part of Form 4473 he needed to sign. Albritton paid the bill and took the receipts. While in the store, Bishop asked Albritton to give him one of the three firearms just purchased. Albritton carried all three firearms out of the store. This transaction was audiotaped and formed the basis for count two of the indictment. Albritton then requested that eight more guns be put on hold for him until he returned the next day, and paid the required deposit.

On August 5, 1988, Albritton returned with Bishop and purchased eight guns. Straach was present in the store but was talking to someone else who was present in the store. Straach acknowledged Albritton and told him that Pischer had started the necessary paperwork for the sale. Pischer then handed Albritton Form 4473, which Bishop filled out for him. No one requested any identification, so none was offered by Bishop or Albritton. Albritton paid for the guns and carried them away. This transaction was audiotaped and formed the basis for count three. Later that same day, Albritton telephoned Straach and informed Straach that he was returning to Oklahoma.

On November 2, 1988, Albritton and Bishop again entered the store and succeeded in purchasing fourteen guns.

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Cite This Page — Counsel Stack

Bluebook (online)
987 F.2d 232, 1993 U.S. App. LEXIS 5059, 1993 WL 76359, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-gary-eugene-straach-ca5-1993.