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United States First Circuit

US v. Munyenyezi, 13-1950

Defendant challenges her conviction and sentence for procuring citizenship illegally by making false statements to the government. Defendant alleges that, in procuring her citizenship, she did not conceal her role in the Rwandan genocide, neither her part in the killing and rapes at the roadblock next to the hotel she and her husband owned together, nor her ties to the political party that incited the genocide. The judgment is affirmed, where: 1) the evidence is sufficient to show that defendant was not a "mere presence" at the roadblock, but rather was deeply involved in the going-ons at the roadblock; 2) the admission of International Criminal Tribunal evidence was not in error, and even if it was in error, such error was a harmless given the vast and damning array of evidence against defendant; 3) the denial of a mistrial was proper given that the circumstances were not so "extremely compelling" as to justify the mistrial; and 4) the two concurrent 120-month sentences are reasonable given the relevant Penal Code section 3553(a) factors for protecting the community and deterring criminal wrongdoing, promoting respect for the law, and providing a just punishment.

Appellate Information

  • Decided 03/25/2015
  • Published 03/25/2015


  • Thompson


  • United States First Circuit


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