United States v. Brown & Meadows case brief summary

United States v. Brown & Meadows case brief summary

FACTS

• The PHA was letting people jump line to get section 8 housing. 
• Meadows was charged and Brown was charged. 
• Brown ran the list while Meadows did not know about the list.

ISSUE

Meadows argued that she lacked the necessary mens rea to commit the act because she didn’t know about the list?

RULE

To hold someone liable there must be evidence that the defendant shared in the criminal intent of the principal.

AIDING & ABETTING STATUTE: 18 USC § 2

i. (a) Whoever commits an offense against the United States or aids, abets, counsels, commands, induces or procures its commission, is punishable as a principal ß prosecuted under this portion

ii. (b) Whoever willfully causes an act to be done which if directly performed by him or another would be an offense against the United States, is punishable as a principal.

HOLDING

Meadows was not involved with the list and wouldn’t have known so she cannot be held liable under three of the four convictions. The court said there was not enough evidence to support an aiding and abetting claim because she was not involved with the waiting list and she didn’t know how it worked.

ANALYSIS

Why didn’t they reverse the fourth?

• Meadows still somewhat participated because she helped her mother fill out the sheet and she knew that her mother would get housing quickly.

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