United States v. Odeh

Rasmieh Odeh (defendant) was a resident of Jordan who had previously lived in Lebanon and Israel. In 1969–1970, Odeh was arrested and convicted in Israel of crimes related to the terrorist bombing of a supermarket and the attempted bombing of a British consulate. Odeh was sentenced to two life terms in prison and was incarcerated until she was released in a prisoner-exchange program in 1979. In 1994, Odeh submitted an immigrant-visa application to the United States. In her application, Odeh answered “no” to questions asking whether she had ever been arrested or convicted of a crime. Her visa was granted, and after living in the United States for approximately 10 years, Odeh applied to become a naturalized citizen in 2004. Odeh again lied about her criminal history in the naturalization-application process, and in person to a government official during an interview. Her naturalization was approved. In 2013, the United States government (plaintiff) discovered evidence of her convictions in Israel and prosecuted her for illegally obtaining citizenship under 18 U.S.C. § 1425(a). At trial, Odeh sought to present expert testimony that she suffered from post-traumatic-stress disorder (PTSD) as a result of torture she suffered at the hands of the Israeli military, and that because of this condition she had not known that her statements were false. The district court did not allow Odeh to present this evidence. Odeh was convicted and sentenced to 18 months’ imprisonment. Odeh appealed, alleging that she was denied the right to present a complete defense.