United States v. Brown

OPINION

SUTTON, Circuit Judge.

A jury convicted David Brown of being a felon in possession of a firearm. 18 U.S.C. § 922(g)(1). Brown moved for a post-verdict judgment of acquittal, arguing that the sole evidence presented against him at trial—his confession—could not support the jury’s verdict. Invoking the “corroboration rule,” the district court agreed with Brown and acquitted him. The United States appeals. Because sufficient independent evidence establishes the trustworthiness of Brown’s statements, we reverse.

I

In April 2006, Jason Helms reported that someone had stolen a Glock .40 caliber…