United States v. Brandon Owens, 15-cr-20201

Government’s Sealed Sentencing Memorandum

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

THE UNITED STATES OF AMERICA,

Plaintiff, Case No.: 15-cr-20201-04

v. HON. MARIANNE O. BATTANI

United States District Judge

D4-BRANDON OWENS,

a.k.a. Little B

Defendant.

GOVERNMENT'S SENTENCING MEMORANDUM

Brandon Owens is a menace to society. He murdered a fellow gang member, 

was caught with a firearm three times (in a 12-month period), has a prior criminal 

record, and actively supports a violent street gang responsible for homicides, 

robberies, and other disturbing crimes. Most alarming is not that Mr. Owens is 

only 20 years old, but that neither court supervision nor committing the ultimate 

act of murder has remotely deterred him from continuing his criminal endeavors. 

There is only one alternative for a defendant who places such little value on life 

and has shown such little remorse—a lengthy term of incarceration. Therefore, the 

government recommends that the court sentence Mr. Owens to a term of 

incarceration of 240 months, followed by a three-year term of supervised release.

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STATEMENT OF FACTS

Related Through Money (“RTM”) is a criminal street gang that committed a 

sundry of crimes including murder, robbery, assault, illegal firearm possession, 

home invasion, carjacking, financial scams, and other offenses. RTM was an 

amalgamation of smaller gangs that unified in order to enhance the ability of the 

gangs to make money, defend territory, increase membership, and gain notoriety. 

Owens explained the relationship between RTM and his sub-group, YNF, well:

RTM claimed territory in northwest Detroit that gang members referred to 

as the “Skuddzone.” Members wrote gang-related graffiti on buildings in their 

territory, including markings such as “RTM da mob” or “RTM world.”

 Owens in front of RTM graffiti RTM graffiti at W. Chicago & Southfield

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RTM members would defend this territory through acts of violence when others 

ventured into the “Skuddzone.” Owens, aka Joyrd Little B on Facebook, publicized 

this fact: 

Owens was a prominent member of RTM. He openly admitted his 

membership in the gang, often boasting on social media regarding his involvement 

in the criminal enterprise. He frequently posted photos of himself on social media 

displaying RTM gang signs, posing with other gang members, and boasting about 

RTM activities. For example, 

 Owens with Deontay McDonald Owens with Deonta Matthews Owens with Meyer Thedford

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Further, Owens was well aware of, and promoted, the criminal activities of 

RTM.

And displayed a particular distaste for those who cooperate with law enforcement.

Importantly, Owens’ gang activities were not limited to boasting on social 

media or informally supporting the gang—he was a “shooter” himself. On March 

22, 2013, Owens was at a party on Greenfield Road in Detroit with several other 

members of RTM. During the party, a physical altercation ensued between 

members of RTM and other individuals at the party. The altercation spilled out into 

the street on Greenfield and a crowd developed in front of the banquet hall. During 

the physical altercation, Owens pulled out a Smith & Wesson revolver from his 

waistband, pointed it toward the crowd, and fired.

The bullet struck Franklin Wallace in the back of the head, killing him.

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Wallace was actually a member of RTM. He apparently stepped in front of 

Owens as Owens discharged the firearm. While the killing of Wallace was

unintentional, the discharge of the firearm at head level into a crowd at a party was 

not. Simply put, Owens’ actions constitute murder in the second degree.

Owens fled the scene of the murder and continued his criminal activities; his

remorse, if any, was short-lived. About a month after killing Wallace, Owens and 

other members of RTM went to Cody High School in an effort to locate and 

intimidate students who were at the party and had witnessed Owens kill Wallace. 

Owens and the other gang members stood outside classroom windows boasting 

about RTM; Owens was brandishing a firearm toward the students, sending a loud 

and clear message. 

Owens’ murdering another person was not exactly unexpected; rather, it was 

in all likelihood just a matter of time. On April 2, 2012, Marcus Cole, aka Squid,

shot RTM member Josh Moore in the face. Squid was a member of rival gang 

Band Crew. Thereafter, Cole was a marked man and was hunted by RTM. In a 

Facebook message on April 12, 2012, Owens stated that he just saw Cole in the 

neighborhood and that he would have shot and killed Cole but Theo (a fellow gang 

member) had his firearm.

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A few weeks later Cole was in fact murdered by RTM leader Deonta Mathews.

Perhaps most remarkable is Owens’ persistent possession of firearms. In his 

own words,

On April 9, 2013, Owens ran from police when officers tried to approach

him as he walked in the neighborhood. During the chase, Owens tossed a black 

handgun to the ground. Officers caught Owens and recovered the firearm, a .38 

caliber Smith & Wesson. Subsequent ballistic testing revealed that this firearm was 

the murder weapon used in the shooting of Franklin Wallace.

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On January 15, 2014, law enforcement officers stopped Owens as he walked 

through the neighborhood to see why he was not in school. During a pat-down, 

officers located a firearm in defendant’s waistband, which had been stolen from a 

residence in Royal Oak six months prior. During an interview with police, Owens 

admitted his membership in RTM. At the time Owens was on probation for 

carrying a concealed weapon.

On May 13, 2014, law enforcement officers responded to a call of shots 

fired. Upon arrival at the scene, officers saw a car pull away and disregard a stop 

sign. Officers stopped the car and during the stop Owen exited the rear passenger

door and fled. Officers pursued Owens and eventually arrested him. During the 

arrest, officers located a firearm in his waistband. The firearm was loaded with 

three live rounds and one spent shell casing. The other two individuals in the car 

with Owens were co-defendant Meyer Thedford and Josh Moore. 

In sum, Owens was caught with a firearm in April of 2013, January of 2014, 

and May of 2014. This is simply astonishing, and criminal charges did little to 

dissuade Owens’ conduct:

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Even being investigated and arrested by the FBI did not deter Owens from 

involving himself in gang activity. The photo below is a snapshot from a video that 

Owens took and posted online from the back of the police cruiser after he was 

arrested by the FBI on this Indictment. 

ADVISORY GUIDELINE RANGE

The parties’ Rule 11 plea agreement calculated the advisory sentencing 

guideline range at 240 months. The probation department arrived at the same 

guideline range. 

SECTION 3553(a) FACTORS

Through 18 U.S.C. § 3553(a) Congress has provided the relevant objectives 

and factors to be considered by sentencing courts in imposing a “sentence 

sufficient, but not greater than necessary.” Those objectives are: (1) the nature and 

circumstances of the offense, and the history and characteristics of the defendant; 

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(2) the need for a sentence to reflect the basic aims of sentencing (including 

retribution, deterrence and rehabilitation); (3) the kinds of sentences legally 

available; (4) the Sentencing Guidelines; (5) Sentencing Commission policy 

statements; (6) the need to avoid unwarranted sentencing disparities among 

defendants with similar records who have been found guilty of similar conduct; 

and (7) the need for restitution. These factors support a sentence of 240 months’

imprisonment. More particularly, a sentence of that length will reflect the 

seriousness of the offense, appropriately punish defendant, protect the public, and 

deter him (and others) from engaging in similar activity.

As discussed above, the conduct that led to defendant’s current criminal 

conviction involved his active participation in a violent street gang. Defendant’s 

criminal conduct encompassed dangerous and violent activities, which included 

murder, witness intimidation, and the illegal possession of firearms. The nature and 

circumstances of the offense warrants a sentence of 240 months.

Owens’ criminal history does not improve upon the bleak picture that his 

participation in these violent crimes paints. Owens is 20 years old and has 

accumulated a lifetime of criminal history. 

The April 9, 2013, arrest for illegal firearms possession led to Owens being 

charged with carrying a concealed weapon. He pleaded guilty to attempted 

carrying a concealed weapon and received three years of probation under the

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Holmes Youthful Trainee Act. Defendant’s time on probation was largely 

unsuccessful—he continued his gang related activities and did not comply with an 

alternative work program. Despite these violations, Owens was given second 

chances; eventually, Owens’ status as a youthful offender was revoked after he 

pleaded to guilty to another firearm offense.

After the January 15, 2014, arrest for a firearm, Owens pleaded guilty to 

carrying a concealed weapon. He was sentenced to one year in jail and three years 

of probation. Defendant’s probation on this case was closed on October 31, 2016, 

presumably due to the plea in the instant case. 

Owens’ criminal activity is not a new occurrence; rather his priors include 

two juvenile adjudications, one for home invasion and one for assault with a 

dangerous weapon. The assault incident stemmed from Owens, accompanied by 

several other RTM members, dispensing pepper spray on a school bus occupied by 

several students.

Notably, defendant was under court supervision during nearly all of his time 

as an RTM gang member. In other words, supervision by the court had zero 

deterrence for defendant’s criminal conduct.

When one considers defendant’s history and characteristics, the only 

reasonable conclusion is that Owens is a dangerous individual who will 

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undoubtedly continue his criminal activity. These facts also makes a sentence of 

240 months appropriate.

In sum, given Mr. Owens’ disturbing and violent conduct, including murder, 

coupled with his criminal history and inability to conform his actions to acceptable 

social norms, there is only one sentencing alternative: a lengthy term of 

incarceration. Given all of the circumstances, the prospect of defendant voluntarily

deterring his criminal behavior in the future is essentially nil. Defendant is a 

significant danger to the community and the public must be protected.

In the end, Mr. Owens’ recurrent and dangerous criminal conduct cannot be 

ignored, discounted, or rationalized. Considering the §3553(a) factors, the 

government recommends that the Court sentence defendant to a term of 

imprisonment of 240 months (as being sufficient but not greater than necessary), 

followed by a three-year term of supervised release. Mr. Owens himself predicted 

this very outcome:

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Respectfully submitted,

BARBARA L. MCQUADE

United States Attorney

s/A. Tare Wigod

A. Tare Wigod

Assistant United States Attorney

211 W. Fort Street, Suite 2001

Detroit, MI 48226

tare.wigod@usdoj.gov

(313) 226-9191

P58479

Dated: November 16, 2016

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CERTIFICATE OF SERVICE

I hereby certify that on November 16, 2016, an employee of the United States 

Attorney’s Office filed the attached document with the ECF system which will send 

notice to 

Jeffrey Edison, attorney for Brandon Owens.

s/A. Tare Wigod

A. Tare Wigod

Assistant United States Attorney

211 W. Fort Street, Suite 2001

Detroit, MI 48226

tare.wigod@usdoj.gov

(313) 226-9191

P58479

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