United States v. De Leon-Ramirez, No. 18-4121 (4th Cir. 2019)Annotate this Case
The Fourth Circuit affirmed the district court's refusal to dismiss defendant's indictment for illegal reentry. Defendant was indicted more than ten years after the government learned that he had unlawfully reentered the United States. The court held that the record supported the district court's factual finding that defendant was fleeing from justice, thus tolling the statute of limitations under 28 U.S.C. 3290. In this case, defendant's aliases and the circumstances surrounding his skipped court dates together support a plausible narrative that he sought to evade prosecution by giving police false information and then twice failing to appear in court when ordered to do so.