Copyright (c) 1996 Tennessee Law Review Association, Inc.
Tennessee Law Review
CASENOTE: CIVIL RIGHTS 42 U.S.C. 1982 EXPANDING PROTECTION TO INCLUDE NON-OWNER USERS OF PROPERTY United States v. Brown, 49 F.3d 1162 (6th Cir. 1995).
63 Tenn. L. Rev. 471
Stephen J. Zralek
On June 9, 1990, Jonathan David Brown met with fellow white supremacists Damion Patton and Leonard William Armstrong in Nashville. 1 The next morning, at approximately 1:00 a.m., the three men rode along West End Avenue in Nashville as Armstrong fired several bullets into a synagogue. 2 Later that morning, Patton was arrested. 3 On June 11, 1990, Patton was released into Brown s custody. 4 Brown told police that Patton would be residing at Brown s apartment, while Patton actually went to live at Brown s farm in Pleasantville, Tennessee. 5 There, Brown informed Patton that the FBI was looking for him. 6 Brown purchased spray paint, helped change the color of the car used in the drive-by shooting, and gave Patton a license plate and cash with which to escape to Las Vegas, where Brown later wired Patton additional money. 7 Almost two years later, on April 22, 1992, Brown was charged as an accessory after the fact to a conspiracy to violate civil rights under 18 U.S.C. 3 and 241, and with perjury under 18 U.S.C. 1623a. 8 The Government alleged that the defendant, Brown, had assisted Patton in hiding from authorities and then lied to the grand jury as to his own involvement in the incident. 9 The defendant asserted that he was innocent of the charges against him, averring that the underlying act by the alleged conspirators was not an offense under 42 U.S.C. 1982 10 and similarly could not have constituted a crime ...
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