United States v. LUCIANA HARMATH

MEMORANDUM

Defendants, Luciana Harmath, Iosif Caza, Manjit Rai, Jagprit Sekhon, and Jagdip Sekhon, appeal in this consolidated federal criminal case. Defendants were convicted of conspiring to commit an offense against or to defraud the United States, in violation of 18 U.S.C. § 371 , by impeding the lawful functions of the Bureau of Citizenship and Immigration Services or by knowingly submitting false immigration documents, in violation of 18 U.S.C. § 1546 (Count One). All Defendants except for Jagdip Sekhon were convicted of conspiring to defraud or commit an offense against the United States, in violation of 18 U.S.C. § 371 , by making false statements in connection with an asylum application, in violation of 18 U.S.C. § 1001 (Count Seventeen). All Defendants except for Jagdip Sekhon also were convicted of one or more counts of aiding and abetting a false statement under 18 U.S.C. § 1001 or 18 U.S.C. § 1546 . We affirm in part and, as to Harmath, Caza, Rai, and Jagprit Sekhon, vacate in part and remand for resentencing.

1. We need not decide whether the admission of the foreign stamps and signatures violated Defendants’ Sixth Amendment rights because any error was harmless…