United States v. Gervais (Ken) Ngombwa

SHEPHERD, Circuit Judge.

The Rwandan Genocide is one of the darkest chapters in human history. Over the span of 100 days, an estimated 800,000 people died. At least a million more were displaced. During and shortly after the tragedy, the United States admitted a limited number of refugees from Rwanda with priority given to those who were in the most danger. Among those admitted were Gervais ("Ken") Ngombwa and purported members of his family. The government alleged and proved at trial that his admission, status, and eventual naturalization were based on material falsehoods. And at sentencing,…