United States v. Kouevi, No. 10-3529 (3d Cir. 2012)
Annotate this CaseKouevi lived in Togo. From 2001- 2005, Kouevi conspired to fraudulently obtain “diversity visas,” 8 U.S.C. 1153(c)), for at least 34 people through the American Embassy in Togo. The head of the scheme, Afolabi, paid fees for persons who were eligible for the diversity lottery and assisted them with their paperwork, requiring the applicants to falsely represent that others were their spouses or children, so that those individuals could obtain visas. Kouevi was responsible for false documents and tutoring participants to prepare them for Embassy interviews. Afolabi helped Kouevi fraudulently obtain his own visa and paid his costs to come to the U.S. The Department of Homeland Security arrested Afolabi for bringing young girls to the U.S. and forcing them to work at hair braiding salons, 16 hours a day, 6 to 7 days a week, for several years, without pay. They were also subjected to beatings and rape. Kouevi was convicted of conspiracy to commit visa fraud, 18 U.S.C. 371, and visa fraud, 18 U.S.C. 1546(a) and 2, and sentenced to 26 months imprisonment. The Third Circuit affirmed, rejecting an argument that his conduct was not criminalized by the part of the statute he was indicted under.
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