United States v. Anguiano-Morfin, No. 11-50376 (9th Cir. 2013)
Annotate this CaseDefendant was convicted under 18 U.S.C. 911 for making a false claim of citizenship. On appeal, defendant challenged the district court's denial of his motion for a new trial. Defendant argued that his misstatement was not willful because he suffered from a delusion that caused him genuinely to believe that he was a United States citizen. The court concluded that the given instructions, considered as a whole, were adequate in the circumstances of this case. Although defendant's requested instruction more clearly articulated the knowledge requirement, the given instruction was adequate under the circumstances because a "misrepresentation... deliberately made" suggested a knowing falsehood. Combined with the testimony and closing arguments at trial, which focused on what defendant knew, the jury was aware that his subjective belief was the dispositive issue. The court also concluded that there was no plain error in the prosecutor's questioning of defendant's expert witness. Accordingly, the court affirmed the judgment.
Court Description: Criminal Law. The panel affirmed a conviction for making a false claim of citizenship in violation of 18 U.S.C. § 911 in a case in which the defendant’s sole defense at trial was that he suffered from a delusion that caused him genuinely to believe that he was a United States citizen. The panel agreed with the defendant that the willfulness element of § 911 requires that the defendant know that the representation is false, but held that the instruction given to the jury was adequate under the circumstances because a “misrepresentation . . . deliberately made” suggests a knowing falsehood. The panel wrote that combined with the testimony and closing arguments at trial, which focused on what the defendant knew, the jury was aware that his subjective belief was the dispositive issue. The panel held that the defendant did not show plain error arising from the prosecutor’s asking the defendant’s expert witness, a doctor, to comment on the defendant’s veracity, where the witness had found the defendant to be truthful as part of the basis for his diagnosis.
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