US Court of Appeals upholds former U.S. Rep. Corrine Brown’s federal fraud convictions

Former U.S. Rep. Corrine Brown’s federal fraud convictions have been affirmed by the U.S. Court of Appeals for the Eleventh District.

Brown appealed her convictions and sentence, saying she mismanaged her finances and put too much trust in her chief of staff Ronnie Simmons. Her appeal centered on whether it was proper to remove a juror from deliberations after they had begun.

In its ruling, the court of appeals wrote, in part: “We find no clear error in the district court’s factual findings. And for that reason, the district court certainly did not abuse its discretion in dismissing Juror 13 from the jury. To hold otherwise would undermine our system of justice by allowing jurors to return verdicts based not on the evidence or law, but instead on a juror’s perceived divine revelation, irrespective of the evidence. Though here, the juror’s perceived divine revelation might have worked in the criminal defendant’s favor had the district court not learned of it mid-deliberations, a contrary holding would allow criminal defendants to be convicted based on a divine revelation divorced from the evidence, rather than the evidence presented at trial — a troubling result, to say the least. And regardless of whether it works in favor of or against the defendant, a rule that would allow a juror to base his verdict on something other than the evidence would be antithetical to the rule of law and is contradicted by decades of precedent. Brown also raises a challenge to the forfeiture order the district court entered. We find no error there, either. We therefore affirm Brown’s convictions.”

Brown went to trial in Jacksonville and was found guilty in May 2017 on 18 of 22 charges. She surrendered for her five-year prison sentence on Jan. 29, 2018.

Brown is serving her sentence at Federal Corrections Institution Coleman’s minimum-security satellite camp in Sumterville. Her convictions represent both the fraud scheme and filing false tax returns and financial disclosures. Prosecutors had sought up to nine years in prison for Brown.

Simmons surrendered Jan. 8, 2018, for his four-year sentence at Federal Corrections Institution Cumberland’s minimum-security satellite camp in Maryland.

Co-conspirator Carla Wiley was released from Federal Prison Camp Alderson in West Virginia on June 5, 2019.

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