In United States v. Jimenez, No. 18-10569 (Aug. 25,
2020) (Hull, Wilson, Lagoa), the Court affirmed the defendant’s immigration-fraud
conspiracy and money laundering convictions.
The Court held that sufficient evidence supported the
immigration-fraud conspiracy conviction because the material misrepresentations he conspired to
make were in documents “required by immigration laws and regulations.” The Court rejected his argument that the
document in question, an I-140 petition, was not such a document. And the Court held that there was sufficient
evidence that the defendant conspired to make false statements in the I-140
petitions in order to obtain visas for Chinese nationals. Because the evidence was sufficient to
support the immigration-fraud conspiracy, the jury could have also convicted
him of money laundering because the visa fraud conspiracy was a “specified
lawful activity” for money-laundering purposes.
