United States v. Vazquez-Rosario, No. 20-1087 (1st Cir. 2022)
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The First Circuit affirmed Defendant's conviction of one count of false impersonation of an employee of the United States, holding that Defendant was not entitled to relief on his claims of error.
On appeal, Defendant primarily challenged the sufficiency of the evidence offered for the jury to convict him. The Supreme Court affirmed, holding (1) Defendant's argument that the "intent to defraud" remains an inherent part of an 18 U.S.C. 9212 violation which the government move prove despite Congress's removal of that language in 1948 was waived for inadequate briefing; and (2) the district court did not abuse its discretion in granting the government's motion to quash a request for testimony of federal officers to corroborate his claims that he was working as an FBI agent at the time of his arrest.
The court issued a subsequent related opinion or order on August 19, 2022.
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