United States v. Jeremy Brown, 888 F.3d 829

On Dec. 25, 2015, Kimberly Brown and her aunt heard gunshots and glass breaking at the aunt’s home; a handgun was found lodged between an outer storm door and an inner locked door.
Ms. Brown and her aunt (Claudia Taylor) identified Jeremy Brown as outside, heard his voice, and reported that he had shot at the house; Ms. Brown made two 9-1-1 calls and an alarm-company call contemporaneous to the events.
The recovered firearm belonged to Ms. Brown; she previously reported it stolen in Sept. 2014 and at that time identified Jeremy Brown as the person who stole it.
Police recovered no spent shell casings outside; Officer testimony included observation of broken door glass and the gun between the doors.
Defendant made recorded jail calls and texts urging Ms. Brown not to answer authorities or to avoid testifying; defendant did not present any evidence at trial.
Jury convicted Jeremy Brown under 18 U.S.C. § 922(g) (felon in possession); he was sentenced to 109 months and appealed, challenging evidentiary rulings and sufficiency of the possession evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove possession under § 922(g)	Government: circumstantial evidence (identifications, 9‑1‑1/alarm calls, gun found outside doors, defendant’s post‑incident efforts to thwart testimony) permits a reasonable jury to infer possession	Brown: it was equally probable Ms. Brown fired or possessed the gun inside; no direct proof defendant possessed or stole the gun	Affirmed — viewed in light most favorable to government, circumstantial evidence was sufficient to support constructive possession finding
Admission of references to defendant’s prior domestic violence (res gestae)	Government: the 9‑1‑1 and alarm calls were contemporaneous background evidence necessary to complete the story of the charged event	Brown: references to a history of domestic violence are extrinsic bad‑act evidence barred by Rule 404(b) and were not intrinsic to proving possession	Abuse of discretion to admit unredacted references to prior domestic violence, but error was harmless because other evidence of guilt was strong and references were minimal

United States v. Soto, 794 F.3d 635 (6th Cir. 2015) (standard of review for sufficiency of the evidence)
United States v. Grubbs, 506 F.3d 434 (6th Cir. 2007) (definition of substantial evidence and deference to jury credibility findings)
United States v. Campbell, 549 F.3d 364 (6th Cir. 2008) (elements required to prove a § 922(g) offense)
United States v. Hardy, 228 F.3d 745 (6th Cir. 2000) (limits on res gestae/background‑circumstances exception to Rule 404(b))
United States v. Clay, 667 F.3d 689 (6th Cir. 2012) (harmless‑error standard for wrongly admitted evidence)