United States v. Brown, 669 F.3d 10

Edward and Elaine Brown engaged in a nine-month standoff with U.S. Marshals after being convicted in a tax-evasion trial and failing to surrender.
Marshals arrested the Browns using surveillance and an undercover operation after initial arrest attempts failed and the Browns resisted at their Plainfield, New Hampshire home.
Post-arrest searches uncovered a large arsenal of weapons, explosives, and ammunition at the Browns’ property.
The Browns were indicted on multiple counts including conspiracy to obstruct federal officers, assaulting federal officers, weapons offenses, felon in possession of firearms, obstruction of justice, and failing to appear.
Edward and Elaine were convicted after an eight-day trial; Edward was sentenced to 37 years and Elaine to 35 years; both appealed arguing numerous trial errors.
The First Circuit consolidated the appeals and upheld the convictions on all grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competency to stand trial	Edward contends no formal competency hearing was required.	Edward claims lack of formal evaluation; competency should be revisited.	No error; no reasonable cause found to doubt competency; no mandatory hearing required.
admissibility of mens rea evidence in tax trial context	Edward argues exclusion of his beliefs about tax laws prevented a complete defense.	Evidentiary rules barred irrelevant or prejudicial defenses; mens rea tied to official duties, not tax laws.	Absence of relevance; defense evidence properly excluded; no constitutional violation.
Hearsay statements and their relevance	Edward argues statements by Browns about threats should be admitted.	Statements were offered to show mens rea or intent; relevance contested.	Statements not hearsay or irrelevant to mens rea; properly admitted or harmless.
Cumulative error doctrine	Elaine asserts multiple evidentiary errors cumulatively require reversal.	Errors, if any, are not prejudicial or not cumulative.	No reversible cumulative error; convictions affirmed.
§ 924(c) jury instructions and verdict form plain error	Wordings like 'in connection with' may misstate § 924(c) elements.	Instructions and verdict form, read as a whole, correctly conveyed elements; no plain error.	No reversible plain error; instructions viewed in their entirety; verdict form adequate.

Dusky v. United States, 362 U.S. 402 (U.S. 1960) (test for competency to stand trial; present ability to consult with counsel and understanding of proceedings)
Ahrendt v. United States, 560 F.3d 69 (1st Cir. 2009) (competency standard; require present ability and understanding)
Robidoux v. O'Brien, 643 F.3d 334 (1st Cir. 2011) (idiosyncratic beliefs do not prove incompetence; underlying mental state considered)
United States v. Troy, 583 F.3d 20 (1st Cir. 2009) (plain-error framework for jury instructions; official duties analysis)
Neder v. United States, 527 U.S. 1 (U.S. 1999) (requirement of precise elements in jury instructions; plain-error standard)
United States v. Meises, 645 F.3d 5 (1st Cir. 2011) (overview testimony; caution against improper government imprimatur)
Flores-de-Jesús v. United States, 569 F.3d 8 (1st Cir. 2009) (overview testimony concerns; admissibility and prejudice considerations)