United States v. Santos Renan Orellana-Blanco

KLEINFELD, Circuit Judge.

This criminal case requires application of the hearsay rule and the confrontation clause to a law enforcement memorandum of an interview.

Facts

Appellant Santos Orellana-Bianco was convicted after a jury trial of marriage fraud 1 and making a false statement on an immigration document. 2 The theory of the prosecution’s case was that he fraudulently married a woman, Beatrice Boehm, to evade restrictions in the immigration laws, and that he lied in his sworn statement and other papers by stating that he was married to her and lived with her when the marriage was actually…