United States v. Alake Ilegbameh

MEMORANDUM

Alake Terry Ilegbameh was convicted of six counts of conspiracy to commit immigration fraud by arranging sham marriages between Nigerian nationals and U.S. citizens in violation of 8 U.S.C, § 1325(c) (knowingly entering into marriage for the purpose of evading immigration laws) and 18 U.S.C. § 1546 (a) (presenting material false statements in immigration documents). We have jurisdiction under 28 U.S.C. § 1291 . We affirm Ilegbameh’s convictions and sentence.

1.The district court did not err in denying a possible request for substitution of counsel. As an initial matter, it is not clear that Ilegbameh actually requested new counsel because he told the district court, “I did not say I need a change of attorney.” Even if Ilegbameh’s letters to and discussion with the district judge are interpreted as a request for new counsel, Ilegbameh failed to make the requisite showing that the conflict between himself and counsel was “so great that it resulted in a total lack of communication preventing an adequate defense.” United States v. Torres-Rodriguez, 930 F.2d 1375, 1380 (9th Cir. 1991), overruled on other grounds by Bailey v. United States, 516 U.S. 137 , 116 S.Ct. 501 ,…