Imagine a brown dwarf of any given mass (between the usual 13j - ~90j mark). It orbits within the outer edge of a reasonably quiet star's habitable zone. Within about 55 million years, it stops fusing deuterium and cools down for the next four-or-so billion years. Its planets, or moons depending on who you ask, have remained in stable orbits for about as long, having settled into a stable resonance without their mass causing their orbits to decay. A few of them, (presumably) above the minimum mass required for tectonic activity, are safely beyond the roche limit, and thus aren't threatened by a runaway greenhouse effect due to tidal stress.
At this point, having been "dead" for so long, would it be possible for life to evolve on the surfaces of the former brown dwarf's satellites? or would any atmospheres have been irreversibly fried due to radiation?