United States v. Munyenyezi

781 F.3d 532 (2015)

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United States v. Munyenyezi

United States Court of Appeals for the First Circuit
781 F.3d 532 (2015)

Facts

In 1994, hundreds of thousands of people in Rwanda, mostly from the Tutsi ethnic group, were killed in a genocide committed by members of the Hutu ethnic group. Beatrice Munyenyezi (defendant) was a Hutu in Rwanda who lived during the genocide in a hotel run by her husband and owned by her mother-in-law. Her husband and mother-in-law were leaders in the Hutu militia and political groups that were responsible for inciting and carrying out the genocide, and the hotel was the scene of a notorious roadblock where fleeing Tutsi people were identified and massacred. Munyenyezi traveled to Kenya as the genocide was ending and applied for refugee status to the United States (plaintiff). On the application forms, Munyenyezi denied having any connection or political affiliation with the perpetrators of the genocide, or of having any personal role. Munyenyezi was granted refugee status and arrived in the United States. Over the next few years, she repeated these denials on immigration-application papers as she became a permanent resident and when she eventually sought and was granted naturalized citizenship. After receiving her United States citizenship, Munyenyezi testified as a witness for her husband during his trial for genocidal crimes before an international criminal court. Munyenyezi’s testimony raised questions about the truth of her previous claims of innocence on her immigration applications, and the United States began investigating her immigration file. Eyewitness accounts provided evidence that Munyenyezi had in fact been personally involved in genocidal crimes. The United States charged Munyenyezi with two counts of procuring citizenship illegally by making false statements. Munyenyezi was convicted and sentenced to two concurrent 10-year prison terms. She appealed, alleging among other claims that the evidence against her was insufficient to prove the crime and that the punishment was unreasonable.

Rule of Law

Issue

Holding and Reasoning (Thompson, J.)

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