United States v. Franki Joseph

Franki Joseph, a Haitian national, challenges his convictions for impersonating a United States citizen, making a false statement on a United States passport application, and aggravated identity theft. He also challenges part of his 35-month sentence.

I

Joseph used the birth certifícate of Christopher Donnell Stevens, a United States citizen, to obtain a Florida identification card that bore Stevens’ name but his own photograph. Joseph then applied for a United States passport using: (1) the fraudulently obtained Florida identification card; (2) another photograph of himself; and (3) Stevens’…