United States v. Rowena Urumelog

MEMORANDUM

1.Sufficient evidence supports Urume-log’s conviction for immigration document fraud under 18 U.S.C. § 1546 (a). A rational jury, “viewing the evidence in the light most favorable to the prosecution,” Jackson v. Virginia, 443 U.S. 307, 319 , 99 S.Ct. 2781 , 61 L.Ed.2d 560 (1979), could have found that the signature attesting to the false statement was Urumelog’s by comparing it to her signature on other documents admitted into evidence. See, e.g., United States v. Alvarez-Farfan, 338 F.3d 1043, 1045 (9th Cir.2003). The jury could also have found that Urumelog knowingly subscribed to this false statement. Urumelog’s visit to the adjudicator regarding the first 1-130 suggests she knew that the first form had been filed when she signed the second.

2. The district court did not abuse its discretion in admitting “other acts” evidence. First, none of the evidence ran afoul of Federal Rule of Evidence 404(b), because each item helped explain Urume-log’s knowledge of the immigration system or her motive for attesting to a false statement. Second, the prejudicial effect of the contested evidence did not substantially outweigh its probative value. See Fed. R.Evid. 403. In…