## Facts

- John Kenneth Brownfield, Jr. was a correctional officer charged in federal court with bribery of a public official.
- Brownfield took bribes from seven inmates in exchange for bringing contraband tobacco into the facility.
- Brownfield admitted the conduct and pleaded guilty.
- The government recommended a sentence of one year and one day, stating this was at the bottom of the applicable Sentencing Guidelines range.
- The sentencing court stated it was not bound by either the government’s recommendation or the advisory Guidelines.
- Brownfield enlisted in the United States Air Force at age 17 and served three wartime tours in Afghanistan and Iraq.
- He served as a firefighter and rescue specialist, received numerous awards, and was honorably discharged in 2005.
- After returning home, Brownfield struggled with alcohol abuse, anger, road rage, hypersexual conduct, and physical fights.
- Brownfield had completed paperwork for a PTSD assessment but remained on a waiting list and had not received meaningful mental-health counseling other than services connected to probation.
- At the sentencing hearing, Brownfield testified credibly and tearfully about his war experiences, including exposure to gruesome casualties and the effects of explosions on soldiers and Afghan adults and children.
- The court considered clinical material, including the Iraq War Clinician Guide, noting that some veterans may initially appear symptom-free after deployment but later develop distress severe enough to require clinical intervention.

## Issues

1. When imposing sentence under 18 U.S.C. § 3553(a), to what extent may a court treat a defendant’s combat service, war trauma, and possible PTSD symptoms as mitigating in a public-official bribery case?
2. How should a sentencing court weigh the seriousness of a correctional officer’s bribery offense and the need for deterrence against the defendant’s history, characteristics, and need for mental-health evaluation and care?

## Decision

- The court treated the Sentencing Guidelines and the government’s recommendation as advisory considerations, not controlling outcomes.
- The court conducted an individualized analysis under § 3553(a), focusing on the offense conduct, Brownfield’s personal history, and the purposes of sentencing.
- The court credited Brownfield’s testimony about combat exposure and considered the Iraq War Clinician Guide’s discussion of delayed or worsening post-deployment symptoms.
- The court viewed Brownfield’s post-service struggles and lack of timely evaluation or counseling as relevant to culpability and to the need for correctional treatment.
- The court also recognized the seriousness of bribery by a correctional officer and the need for punishment and deterrence to protect institutional order and public trust.
- After balancing these considerations, the court imposed a sentence based on its § 3553(a) assessment rather than simply adopting the government’s bottom-of-range recommendation.

## Legal Principles

- After *United States v. Booker*, the Sentencing Guidelines are advisory; the sentencing court must consider the Guidelines but must ultimately impose a sentence consistent with § 3553(a).
- A sentencing judge is not bound by the parties’ sentencing recommendation and must make an independent determination of the appropriate sentence.
- Section 3553(a) requires consideration of the nature and circumstances of the offense, the defendant’s history and characteristics, and the purposes of sentencing, including just punishment, deterrence, protection of the public, and needed medical care.
- Military service and credible evidence of combat-related trauma, including PTSD-like symptoms and delayed onset of distress, may be relevant mitigating information at sentencing without excusing criminal conduct.
- Public-corruption offenses by correctional staff implicate public trust and institutional security, supporting meaningful deterrence even where the contraband is tobacco rather than drugs or weapons.
- Courts may consult reliable clinical and governmental materials when evaluating claimed mental-health effects and treatment needs as part of a § 3553(a) analysis.

## Conclusion

In *Brownfield v. United States*, the district court sentenced a correctional officer who accepted inmate bribes to smuggle tobacco by applying an individualized § 3553(a) analysis, crediting credible evidence of combat-related trauma and possible PTSD symptoms (including clinical material about delayed post-deployment distress) while still accounting for the gravity of abusing a position of trust and the need for punishment and deterrence.


Brownfield v. United States, No. 08-cr-00452-JLK (2009)