United States v. Larelle Cromity

CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 3, 2025
Docket24-3066
StatusUnpublished

This text of United States v. Larelle Cromity (United States v. Larelle Cromity) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth 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. Larelle Cromity, (6th Cir. 2025).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 25a0002n.06

Case No. 24-3066

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jan 03, 2025 ) KELLY L. STEPHENS, Clerk UNITED STATES OF AMERICA, ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) ) THE NORTHERN DISTRICT OF LARELLE CROMITY, OHIO ) Defendant-Appellee. ) OPINION )

Before: THAPAR, NALBANDIAN, and RITZ, Circuit Judges.

THAPAR, Circuit Judge. After Larelle Cromity pled guilty to being a felon in possession

of ammunition, the district court applied two sentencing enhancements: one for using bullets in

connection with another felony, and another for obstructing justice. Cromity now argues those

enhancements make his sentence procedurally unreasonable. They don’t, so we affirm.

I.

This case stems from a traffic incident in Cleveland. After a car turned in front of Larelle

Cromity’s truck, Cromity honked, leaned out the window, and swore at the driver. When the other

driver opened the door and pointed towards the truck, Cromity, a felon, brandished a handgun at

the car. The other driver got back in and drove off. But Cromity opened fire and shot five bullets

towards the fleeing car while multiple children played nearby. Numerous shell casings fell onto

the street. Cromity then fled the scene. No. 24-3066, United States v. Cromity

Police arrived ten minutes later. They collected the casings and investigated the source of

the shots. A witness also said the car driver fired at Cromity’s truck. As part of the inquiry, police

learned that two cameras—a surveillance camera and a Ring video camera—captured the whole

event. When police reviewed the tapes, they saw that the truck driver opened fire at the car as it

sped away. And they never saw the car driver wield a gun or shoot. The tapes also let officials

identify Cromity as the truck driver. They arrested him soon after.

Cromity then made several incriminating statements. First, he told investigators that he

knew he’d been convicted of felonies, and that these crimes meant he couldn’t have the bullets he

fired. But Cromity claimed that the car driver had first pointed a firearm at him and threatened to

“shoot his face off.” R. 21, Pg. ID 111. (A witness on the scene also informed police that someone

made this statement.) Cromity also reported that he didn’t have the gun because he melted it down.

A grand jury indicted Cromity for being a felon in possession of ammunition, in violation

of 18 U.S.C. §§ 922(g)(1) and 924(a)(8), and he pled guilty.

The presentence report (“PSR”) proposed applying a four-level enhancement under

U.S.S.G. § 2K2.1(b)(6)(B) for possessing the ammunition in connection with another felony

offense, namely firing weapons in an area where children are present. And it proposed applying a

two-level enhancement under U.S.S.G. § 3C1.1 for obstructing justice because Cromity melted

and destroyed his firearm.

Cromity raised two objections that are relevant here. First, he asserted that he fired his gun

in self-defense only after seeing the car driver’s weapon, so he didn’t commit a felony. Second,

he claimed that he didn’t willfully obstruct justice. He alleged that there was no evidence he had

access to a furnace that could melt a gun. And, if he did melt the gun, he claimed that he didn’t

intend to obstruct the administration of justice.

-2- No. 24-3066, United States v. Cromity

At sentencing, the court applied both enhancements, resulting in a Guidelines range of 120

to 150 months. The court imposed a 144-month sentence, followed by three years of supervised

release. Cromity appealed.

II.

On appeal, Cromity argues that the district court’s decision to apply both enhancements

renders his sentence procedurally unreasonable. His arguments about both provisions fail.

A.

Cromity first challenges the district court’s application of § 2K2.1(b)(6)(B). Because the

district court didn’t err, Cromity’s claim falls short.

1.

A defendant receives a four-point enhancement if he “used or possessed any firearm or

ammunition in connection with another felony offense.” U.S.S.G. § 2K2.1(b)(6)(B). A “felony

offense” is a federal, state, or local offense that’s punishable by more than a year in prison, even

if it were never charged. Id. § 2K2.1(b)(6)(B) cmt. n.14(C). And using the firearm or ammunition

“in connection” with another offense means that “the firearm or ammunition facilitated . . . another

felony offense.” Id. § 2K2.1(b)(6)(B), cmt. n.14(A). In other words, the possession of a firearm

or ammunition can’t be “merely coincidental.” United States v. Ennenga, 263 F.3d 499, 503 (6th

Cir. 2001). Instead, the government must establish that there’s a nexus between the firearm and

the felony. United States v. Burns, 498 F.3d 578, 580 (6th Cir. 2007).

When looking at a court’s application of § 2K2.1(b)(6)(B), we “review the district court’s

factual findings for clear error, and accord ‘due deference’ to the district court’s determination that

the firearm was used or possessed ‘in connection with’ the other felony.” United States v. Taylor,

648 F.3d 417, 432 (6th Cir. 2011) (citation omitted).

-3- No. 24-3066, United States v. Cromity

2.

The district court correctly found that Cromity used or possessed his ammunition in

connection to his felony offenses. Cromity’s decision to shoot could have amounted to two Ohio

felonies: felonious assault and discharging a firearm over a public road or highway. And the

ammunition played a key role in both offenses—Cromity wasn’t firing blanks. Thus, the court

correctly applied § 2K2.1(b)(6)(B).

Cromity responds that he was acting in self-defense, and thus didn’t commit a felony at all.

He asserts the car’s driver pointed what Cromity perceived to be a gun at him. Therefore, says

Cromity, he believed he was in imminent danger of death or great bodily harm, and could return

fire. Cromity also notes that one witness said the car driver also fired a gun during the incident.

Cromity’s arguments require looking at Ohio’s self-defense regime. To make out a self-

defense claim under Ohio law, a plaintiff must make three showings. Ohio v. Jackson, 490 N.E.2d

893, 896–97 (Ohio 1986) (per curiam). First, he must prove he wasn’t at fault in starting the

incident. Id. at 896. Second, he must show that he had a “bona fide” belief that he faced imminent

danger of death or great bodily harm and that his only way to escape was using force. Id. at 896–

97. Third, he must demonstrate he violated no duty to retreat or avoid the danger. Id. at 897. If a

defendant fails to prove any element, then he didn’t act in self-defense.

Cromity can’t meet two elements of a self-defense claim. The district court found that

Cromity started the incident when he swore at the car’s driver. So he was at fault for instigating

the incident. And Cromity also didn’t face imminent death or danger when he opened fire. Why?

Cromity didn’t shoot until the car was driving away, meaning he used deadly force without a

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Related

United States v. Taylor
648 F.3d 417 (Sixth Circuit, 2011)
United States v. Ronald Alan Ennenga
263 F.3d 499 (Sixth Circuit, 2001)
United States v. Robert Paul Boyd
312 F.3d 213 (Sixth Circuit, 2002)
United States v. Burns
498 F.3d 578 (Sixth Circuit, 2007)
United States v. Tirrell Thomas
933 F.3d 605 (Sixth Circuit, 2019)
State v. Jackson
490 N.E.2d 893 (Ohio Supreme Court, 1986)

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United States v. Larelle Cromity, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-larelle-cromity-ca6-2025.