The U.S. Court of Appeals for the Fourth Circuit affirmed the conviction of Charmaine Miesha Brown on multiple federal fraud charges in an unpublished per curiam opinion filed Jan. 13, 2026. Brown was sentenced to 30 months in prison after a federal jury found her guilty of conspiracy to commit passport fraud, conspiracy to commit wire fraud, bankruptcy fraud, and making false statements in bankruptcy proceedings.

The case, *United States v. Charmaine Miesha Brown* (4th Cir. 2026), originated in the U.S. District Court for the District of Maryland under Judge Theodore D. Chuang. The three-judge panel consisting of Circuit Judges Gregory, Thacker, and Heytens unanimously upheld the district court's judgment without issuing a published opinion.

According to court documents, the fraud scheme involved Brown and her codefendant Andrews Oduro Brown, whom she married in January 2014. Oduro, a Ghanaian national who entered the United States in May 2013, worked with Brown to fraudulently obtain U.S. passports for his two Ghanaian children by making false claims about their citizenship status.

The jury convicted Brown on four separate counts under federal law. The conspiracy to commit passport fraud charge was brought under 18 U.S.C. § 371, which criminalizes conspiracies to commit offenses against the United States. The wire fraud conspiracy charge fell under 18 U.S.C. § 1349, which targets schemes to defraud using electronic communications.

Additionally, Brown faced bankruptcy-related charges including bankruptcy fraud under 18 U.S.C. § 157(1) and false statements in bankruptcy proceedings under 18 U.S.C. § 152(3). These statutes carry significant penalties for those who attempt to defraud bankruptcy courts or creditors through false documentation or misleading statements.

The passport fraud conspiracy represents a serious federal offense, as U.S. passports are critical identity documents that establish citizenship and enable international travel. Federal authorities have increased enforcement of passport fraud cases in recent years, recognizing the national security implications of fraudulent travel documents.

Wire fraud conspiracy charges often accompany passport fraud cases when defendants use electronic communications like email, phone calls, or online applications to further their schemes. The conspiracy charges indicate that prosecutors proved Brown worked with at least one other person to plan and execute the fraudulent activities.

The bankruptcy fraud charges suggest Brown's criminal activity extended beyond passport fraud to include attempts to deceive bankruptcy courts. Bankruptcy fraud typically involves hiding assets, making false statements about financial circumstances, or attempting to discharge debts through fraudulent means.

Brown's legal representation came from Stuart A. Berman of Lerch, Early & Brewer, Chartered, based in Bethesda, Maryland. The government was represented by U.S. Attorney Kelly O. Hayes and Assistant U.S. Attorneys David C. Bornstein and Brandon K. Moore from the Baltimore office.

The Fourth Circuit's decision to issue an unpublished per curiam opinion means the ruling will not establish binding precedent for future cases in the circuit. Unpublished opinions typically address straightforward applications of established law rather than novel legal questions requiring detailed analysis.

The appeal was submitted to the Fourth Circuit on Dec. 30, 2025, and decided just two weeks later on Jan. 13, 2026, indicating the court found no merit in Brown's appellate arguments. The rapid turnaround suggests the legal issues presented were not complex or that Brown's challenges to the conviction lacked substantial basis.

Federal sentencing guidelines for fraud offenses consider factors including the amount of intended loss, the number of victims, and the defendant's role in the scheme. Brown's 30-month sentence falls within typical ranges for multi-count fraud cases involving passport and bankruptcy violations.

The case highlights federal authorities' continued focus on prosecuting document fraud, particularly involving immigration-related documents like passports. Such cases often involve complex family relationships and cross-border elements that require coordination between multiple federal agencies.

The Fourth Circuit's affirmance means Brown's conviction and sentence will stand unless she seeks review by the Supreme Court, which is unlikely given the case's fact-specific nature and lack of novel legal issues. The conviction serves as a warning to others who might consider similar fraudulent schemes involving federal identity documents.

This case demonstrates the serious consequences of passport fraud and related offenses, which federal prosecutors view as threats to national security and immigration integrity. The successful prosecution and appeal affirmance reinforce the government's commitment to pursuing such cases vigorously through the federal court system.