Brown v. United States

WASHINGTON, Chief Judge.

After a jury trial, appellant Henry Brown (“Brown”) was convicted of two counts of unlawful distribution of a controlled substance 1 and one count of unlawful possession with intent to distribute a controlled substance. 2 On appeal, Brown contends that the trial court committed prejudicial error when it instructed the jury (1) that the government had “no duty” to collect corroborative evidence; and (2) that the jury’s verdict must be based “solely on the evidence presented at the trial,” arguing that the combination of these instructions prevented the jury from finding…