United States v. Kantengwa, No. 12-2259 (1st Cir. 2015)
Annotate this CaseDefendant, a member of a prominent political family allegedly involved in the Rwandan genocide, was convicted of perjury and obstruction of justice based on false statements she made in connection with her application for asylum in the United States and subsequent removal proceedings. The false statements concerned Defendant’s truthfulness on previous immigration documents, in which she misrepresented her political affiliations and government employment, and her statement that there was no roadblock outside Hotel Ihuriro during her stay there at the start of the genocide. The First Circuit affirmed the convictions, holding (1) the district court did not err in denying Defendant’s motion to dismiss on grounds of collateral estoppel, as collateral estoppel did not apply on the facts of this case; (2) the government succeeded in establishing that Defendant’s false statements were material to the immigration judge’s decision; and (3) the district court did not abuse its discretion in admitting the testimony of a professor of political science and an expert on the Rwandan genocide as to the existence of a roadblock in front of Hotel Ihuriro before Defendant’s departure.
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