United States v. Osama Musa Alferahin

433 F.3d 1148, 2006 U.S. App. LEXIS 575, 2006 WL 51181
CourtCourt of Appeals for the Ninth Circuit
DecidedJanuary 11, 2006
Docket04-10590
StatusPublished
Cited by98 cases

This text of 433 F.3d 1148 (United States v. Osama Musa Alferahin) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Osama Musa Alferahin, 433 F.3d 1148, 2006 U.S. App. LEXIS 575, 2006 WL 51181 (9th Cir. 2006).

Opinions

BETTY B. FLETCHER,

Circuit Judge.

Osama Musa Alferahin appeals his conviction under 18 U.S.C. § 1425(a) for knowingly procuring naturalization “contrary to law.” The basis for this conviction was Alferahin’s failure to disclose, on an application for permanent resident status, that he had been previously married. On appeal, Alferahin contends that the district court erred by failing to instruct the jury that 18 U.S.C. § 1425(a) contains a requirement of “materiality.” Alferahin further contends that his attorney’s failure to obtain an instruction on the issue of materiality constituted a denial of his right to effective assistance of counsel under the Sixth Amendment. We reverse his conviction and remand for a new trial.

I.

Osama Musa Alferahin was born in Kuwait as a citizen of Jordan. He has married twice. He married his first wife— Alicia Jaremo Y Pradeñas, a citizen of Spain — on February 27, 1995. According to Alferahin, he divorced her in a religious ceremony at the Islamic Cultural Center in Madrid, Spain, on September 1, 1997. That divorce, however, was not officially recorded in the Spanish civil registry until February 16, 2000.

Alferahin married his second wife— Reem Alferahin, a naturalized citizen of the United States — on December 31, 1997, in Amman, Jordan. A little more than one month later, on February 2, 1998, he applied for permanent residence in the United States based on his status as the spouse of an American citizen. Alferahin thus married his second wife and applied for permanent residence in the United States after the religious ceremony in Spain in which he claims to have divorced his first wife, but before the Spanish civil registry had recorded that divorce officially.

As part of Alferahiris application for permanent residence, his second wife signed and submitted a petition known as Form 1-130. Because Form 1-130 involves an application for permanent residence based on an alien’s marriage to an American citizen, this form requires the petitioner to disclose the existence of any and all [1152]*1152previous marriages involving either the United States citizen or the alien-spouse, as well as the date of the dissolution of those marriages. Alferahin, who testified that he prepared Form 1-130 himself on behalf of his wife, provided inaccurate information on this form. In response to questions about the existence and dissolution of previous marriages, Alferahin responded “N/A,” implying that the questions were not applicable to him.

On the basis of the information submitted on Form 1-130, Alferahin obtained status as a permanent resident. Two years later, in May of 2002, Alferahin became a naturalized citizen. More than one year after obtaining citizenship — and more than five years after he submitted his application for permanent residence — -Alferahin was arrested and charged with the crime of knowingly procuring naturalization contrary to law. See 18 U.S.C. § 1425(a)(pun-ishing those who “knowingly procure! ] or attempt! ] to procure, contrary to law, the naturalization of any person, or documentary or other evidence of naturalization or of citizenship”).

At trial, the government contended that Alferahin deliberately withheld information about his first marriage from his application. According to the government, Alferahin had explained to an INS investigator that he omitted the information because he “didn’t want to complicate the process.” The government further emphasized that the omitted information was pertinent to Alferahin’s application because his petition for permanent residence depended on the validity of his second marriage to an American citizen. The disclosure of truthful information, the government contended, would have led immigration officials to investigate the dissolution of Alferahin’s first marriage and to inquire into the validity of his second.

In opposition to the government’s position, Alferahin provided a culturally based explanation for the inaccuracies. He explained that, in Moslem culture, a man may have multiple wives and need not disclose his marital status; he claimed that due to this cultural background, he had responded “not applicable” based on his belief that the questions literally did not apply to him. The defense also downplayed the significance of the omitted information. For instance, Alferahin’s wife testified that they considered information about his marital status “just not important.” In addition, defense counsel cross-examined the government’s witnesses on the likely consequences of a complete disclosure by Alferahin, suggesting that the INS would have processed his application for permanent residence in exactly the same fashion if Alferahin had revealed the existence of his first marriage.

At the conclusion of the trial, the district court noted that there were “no stock instructions on this particular crime.” Since neither side had proposed jury instructions on the elements of the charged offense, the district court drafted instructions on its own for the attorneys to review. There was no mention of the need for an instruction on materiality.

During closing arguments, however, both the prosecution and the defense called the jury’s attention to the significance of the omitted information. The prosecution argued that Alferahin had “concealed a material fact,” adding that the existence of Alferahin’s first marriage “is a material fact because we need to know if there’s some sort of marriage fraud going on.” 1 By contrast, the de[1153]*1153fense underscored the insignificance of the information, emphasizing that “we’re arguing over what is an irrelevant fact” and noting that the government’s witnesses had not testified that Alferahin’s application would have been denied even if Alferahin had properly disclosed his first marriage. Alferahin’s attorney argued: “No one is even suggesting that Osama would not have been granted citizenship if he had put Alicia’s name and their divorce dates ... on the 1-130.”

During the middle of closing arguments, the district court noted this emphasis on materiality and, sua sponte, raised the question of a materiality instruction. Pointing to the government’s argument that Alferahin’s omission had been material, the district judge noted that materiality was not one of the elements included in the jury instructions and suggested that “perhaps it should have been.” The government responded that the proposed instructions “mirror[ed] the statute.” But the government did not object to the materiality instruction, adding that “we have always put in all of our proof with respect to this case that it was material, to cover ourselves, ... because in other statutes that we were contemplating charging the defendant with, materiality was always an issue.”

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Bluebook (online)
433 F.3d 1148, 2006 U.S. App. LEXIS 575, 2006 WL 51181, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-osama-musa-alferahin-ca9-2006.