United States v. Rodney Brown, 21-5716

Rodney Brown had two Michigan sex-offense convictions (1987; 1992). The 1992 conviction was a Tier III offense under SORNA, requiring lifetime registration.
Brown registered in Michigan after release but moved to Memphis, Tennessee in mid-2015 and did not notify authorities or update his registration.
Michigan identified Brown as an absconder after he applied for a Tennessee ID in July 2018; federal investigators obtained certified conviction records and charged him under 18 U.S.C. § 2250(a) for failing to register.
At trial Brown sought to stipulate to the prior conviction while omitting details; the government refused, the court proposed a modified stipulation, and defense counsel ultimately withdrew the stipulation on the record.
Supervisory Deputy U.S. Marshal James Edge testified about SORNA, the registries, his investigation, and authenticated Brown’s signatures on registration documents.
The jury convicted Brown; the district court sentenced him to 45 months’ imprisonment and five years supervised release.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by refusing the defense stipulation to prior conviction (Old Chief claim)	Government: admission of conviction details was proper because prior convictions are relevant to elements of §2250(a).	Brown: refusal prevented him from avoiding prejudicial details; court should have accepted a limited stipulation.	Waiver — defense counsel expressly withdrew the stipulation on the record; issue not preserved. Also Old Chief is limited to felon-in-possession context. Affirmed.
Whether the government improperly used Edge as a hybrid expert/fact witness without disclosure or a limiting instruction	Government: Edge’s testimony was lay background and based on personal investigation and records, not expert opinion; admissible without expert disclosure or limiting instruction.	Brown: Edge crossed into expert/fact-opinion territory without qualification and no limiting instruction was given, prejudicing his defense.	No plain error — Edge’s testimony was proper background/fact testimony (and authenticated signatures properly); any error would be harmless given overwhelming evidence. Affirmed.

Old Chief v. United States, 519 U.S. 172 (1997) (limits defendant’s ability to avoid admissible conviction details by stipulation only in felon-in-possession context)
United States v. Kilpatrick, 798 F.3d 365 (6th Cir. 2015) (distinguishing background lay testimony from opinion testimony under Rule 701)
United States v. Adams, 722 F.3d 788 (6th Cir. 2013) (test for evidence “inextricably intertwined” as background to charged offense)
United States v. Harris, 786 F.3d 443 (6th Cir. 2015) (agents may authenticate handwriting via familiarity gained in investigation under Rule 901(b)(2))
United States v. White, 492 F.3d 380 (6th Cir. 2007) (standard for reviewing expert/opinion testimony and harmless-error analysis)
United States v. Baker, 458 F.3d 513 (6th Cir. 2006) (harmless-error framework for evidentiary mistakes)
Olano v. United States, 507 U.S. 725 (1993) (waiver doctrine: intentional relinquishment of a known right extinguishes appellate review)
United States v. Mabee, 765 F.3d 666 (6th Cir. 2014) (waiver by explicit on-the-record concession)