Government's Change of Plea Memorandum — United States v. Kasim Brown (Document 16, filed March 31, 2026)

Summary

This is the government's change of plea memorandum in the Eastern District of Pennsylvania, Criminal No. 25-425, United States of America against Kasim Brown. It says Brown is charged in a one-count indictment with possession of a firearm by a felon and expressed an intention to plead guilty, with a hearing scheduled before the Honorable Joel Harvey Slomsky on April 7, 2026. It lists a maximum of fifteen years' imprisonment, a three-year term of supervised release, a $250,000 fine and a $100 special assessment. The factual basis recounts a July 9, 2025 robbery investigation, a video on a phone, and an ATF agent's determination that the firearm was not manufactured in Pennsylvania. It says a plea agreement was executed, with a supplement to be filed under seal.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

        Case 2:25-cr-00425-JHS           Document 16        Filed 03/31/26      Page 1 of 5




                         IN THE UNITED STATES DISTRICT COURT

                      FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA                               :

                 v.                                    :       CRIMINAL NO. 25-425

KASIM BROWN                                            :

                  GOVERNMENT’S CHANGE OF PLEA MEMORANDUM

I.     Background

       Defendant Kasim Brown is charged in a one-count indictment with the possession of a

firearm by a felon, in violation of 18 U.S.C. § 922(g)(1). The defendant expressed his intention

to plead guilty to Count One. The government is also seeking criminal forfeiture of the firearm.

A change of plea hearing has been scheduled before the Honorable Joel Harvey Slomsky on

April 7, 2026.

II.    Applicable Statute and Essential Elements of the Offense

                 Possession of a firearm by a felon, in violation of Title 18, United States Code,
                 Section 922(g)(1)

       Title 18, United States Code, Section 922(g)(1) provides, in pertinent part, “It shall be

unlawful for any person . . . who has been convicted in any court of, a crime punishable by

imprisonment for a term exceeding one year . . . to . . . possess in or affecting commerce, any

firearm or ammunition.”

       To convict the defendant of possession of a firearm by a felon, the government must

prove the following four elements:

                 1.     The defendant knowingly possessed a firearm;

                 2.     At the time of the charged act, the defendant had previously been

                                                  1
       Case 2:25-cr-00425-JHS          Document 16        Filed 03/31/26      Page 2 of 5




                      convicted in a court of a crime punishable by imprisonment for a term

                      exceeding one year;

              3.      At the time of the charged act, the defendant knew that he had been

                      convicted of such an offense; and

              4.      Such possession was in or affecting interstate commerce.

III.   Maximum Penalties

       Count One– Possession of ammunition by a felon – 18 U.S.C. § 922(g)(1):

       The defendant faces a maximum sentence of fifteen years’ imprisonment, a three-year

term of supervised release, a $250,000 fine, and a $100 special assessment.

IV.    Factual Basis for the Plea

       Philadelphia police department (“PPD”) detectives developed Kasim BROWN as a

suspect in a July 9, 2025, robbery of N.D. at “Milkboy” music studio located on the 400 block of

N. 7th Street. The robbery occurred at approximately 10:30 p.m. and is captured on video. The

offenders produced handguns and utilized cell phones during the course of the robbery.

Detectives identified BROWN as a suspect in that robbery and issued a warrant for his arrest.

       Detectives additionally applied for and obtained a search warrant for BROWN’s

residence. When SWAT officers executed the warrant for Apartment 3C, they saw a black male

throw an AR-style rifle out of the window of the building. The window belonged to an adjacent

apartment. Members of Central Detectives knocked on the apartment door of 3D with no

response. PPD officers then secured the door to the apartment while detectives obtained a search

warrant for Apartment 3D. BROWN and two other individuals were located in the apartment.

Officers called BROWN’s cell phone number (which was previously provided by his probation


                                                2
        Case 2:25-cr-00425-JHS          Document 16        Filed 03/31/26      Page 3 of 5




officer) and located an iPhone in the apartment.

       Detectives applied for and obtained a search warrant for BROWN’s cell phone. Federal

investigators additionally obtained a federal search warrant for BROWN’s cell phone. In the

phone, investigators located a first-person video of BROWN with a handgun. The video was

taken the night of the robbery, July 9, 2025, at 8:02 p.m. — approximately two-and-a-half-hours

before the robbery. The video depicts the arm of a black male wearing a gray shirt and ripped

jean pants opening a black book bag and retrieving two Glock pistols from the bag. A closer

review of the video shows there is a tattoo on the left hand of the individual retrieving the

firearms which reads “BEYOND BLESSED.” BROWN has an identical tattoo on his hand.

Additionally, the voice of the person taking the video is very distinctive. Investigators familiar

with BROWN have identified the voice as belonging to BROWN.

       The firearm was recovered from another individual on September 9, 2025, in West

Philadelphia. The firearm was submitted to the Firearms Identification Unit for analysis; it was

test fired and entered into NIBIN.

       Special Agent Shiva Raja from the Bureau of Alcohol, Tobacco, Firearms and Explosives

(“ATF”), an expert in the field of interstate/foreign nexus of firearms analyzed the still image of

the firearm. Special Agent Raja determined that the firearm was not manufactured in

Pennsylvania and thus traveled through and affected interstate or foreign commerce.

       On June 7, 2022, BROWN pled guilty to two violations of the Pennsylvania Criminal

Code and signed a written guilty plea form acknowledging that his crimes were punishable by

2.5 – 5 years in prison each, for a total statutory maximum of 10 years’ incarceration – therefore

he was aware he had been convicted of a crime punishable by more than one year of


                                                   3
        Case 2:25-cr-00425-JHS         Document 16        Filed 03/31/26     Page 4 of 5




incarceration at the time of the commission of the instant offense.

V. Plea Agreement

        The parties have executed a plea agreement that will be presented to the Court during a

hearing regarding entry of the guilty plea. The agreement includes a supplement to be filed under

seal.

VI. Conclusion

        The United States requests that the Court conduct a hearing under Federal Rule of

Criminal Procedure 11 and accept the defendant’s plea of guilty.

                                             Respectfully submitted,

                                             DAVID METCALF
                                             United States Attorney

                                             /s/ Ashley N. Martin
                                             ASHLEY N. MARTIN
                                             Assistant United States Attorney




                                                 4
       Case 2:25-cr-00425-JHS          Document 16         Filed 03/31/26      Page 5 of 5




                                CERTIFICATE OF SERVICE

           I hereby certify that on this date I caused a true and correct copy of the foregoing to

be served via electronic mail upon the following:

                                     Shaka Johnson, Esquire
                                  shaka@shakajohnsonlaw.com




                                              /s/ Ashley N. Martin
                                              ASHLEY N. MARTIN
                                              Assistant United States Attorney

Dated: March 31, 2026




                                                 5


File and source

File

16.pdf

Size

213,141 bytes

SHA-256

f8866e96a39a85333102bf189c9311307189654d5839d698e492102465f3c2f4

Our copy

16.pdf

Original

No public link identified.