United States v. Brown & Meadows

Brown and Meadows (defendants), who were personal friends, worked for the Detroit Housing Department (DHD) on the Section 8 housing program, a federal program that provides financial assistance to eligible low-income families so they can rent housing from private landlords. Meadows worked as a housing-eligibility investigator, and Brown was responsible for administering the Section 8 program. The program regulations require that eligible applicants be selected based on certain criteria and that applicants be placed on a waiting list and chosen to receive subsidies in a particular order. The selected applicants were given certificates or vouchers that entitled them to rental subsidies. During Brown’s tenure as administrator of the program, several certificates and vouchers that Brown signed were improperly issued to individuals who would not have been selected from the waiting list, including friends and family members of Meadows, political cronies, and senior citizens connected to an individual who paid bribes to Brown. Brown and Meadows were indicted for making false statements to a federal agency based on the improperly issued certificates and vouchers. The United States (plaintiff) alleged that eligibility meant the recipient of a certificate or voucher had come off a waiting list, and therefore in issuing certificates and vouchers to individuals who had not come off a waiting list, Brown and Meadows falsely represented that the recipients were eligible to receive subsidies. Brown and Meadows were convicted after trial. On appeal, Meadows, who was convicted for aiding and abetting Brown’s false-statement violations, argued that she did not have the necessary mens rea for conviction.