  We examine recent claims that the T-type brown dwarf S Ori 053810.1-023626 (S
Ori 70) is a spectroscopically verified low mass (3$^{+5}_{-1}$ M$_{Jup}$)
member of the 1--8 Myr $\sigma$ Orionis cluster. Comparative arguments by
Mart{\'{i}}n & Zapatero Osorio asserting that S Ori 70 exhibits low surface
gravity spectral features indicative of youth and low mass are invalidated by
the fact that their comparison object was not the field T dwarf 2MASS
0559$-$1404 but rather a nearby background star. Instead, we find that the
1--2.5 $\micron$ spectra of S Ori 70 are well-matched to older (age $\sim$ few
Gyr) field T6--T7 dwarfs. Moreover, we find that spectral model fits to
late-type field T dwarf spectra tend to yield low surface gravities ($\log{g}$
= 3.0--3.5), and thus young ages ($\lesssim$ 5 Myr) and low masses ($\lesssim$
3 M$_{Jup}$), inconsistent with expected and/or empirical values. Finally, we
show that the identification of one T dwarf in the field imaged by Zapatero
Osorio et al. is statistically consistent with the expected foreground
contamination. Based on the re-examined evidence, we conclude that S Ori 70 may
simply be an old, massive (30--60 M$_{Jup}$) field brown dwarf lying in the
foreground of the $\sigma$ Orionis cluster. This interpretation should be
considered before presuming the existence of so-called ``cluster planets.''
