United States v. Torralba-Mendia

Miguel Torralba-Mendia (defendant) was charged with conspiring to smuggle undocumented immigrants into the United States. At Torralba-Mendia’s trial, the United States (plaintiff) introduced into evidence I-213 immigration forms for Torralba-Mendia’s passengers who had been detained during the government’s investigation. The forms, which were labeled “Record of Deportable/Inadmissible Alien,” were regularly filled out and kept by the Department of Homeland Security (DHS). Each form contained information including the alien’s name, photograph, fingerprints, and date and method of departure from the United States, and each was signed by a Customs and Border Patrol agent. The forms also contained the agent’s statement regarding how the alien was caught and statements from the alien about his or her country of origin and address. The government redacted the agents’ and aliens’ statements before introducing the forms into evidence. The government used the forms to show that many passengers detained during the investigation were deported. A jury convicted Torralba-Mendia, and he appealed to the United States Court of Appeals for the Ninth Circuit. Torralba-Mendia argued on appeal that the I-213 forms contained inadmissible hearsay and that admitting them into evidence violated his constitutional right to confront the witnesses against him.