United States v. Phoeun Lang

THOMPSON, Circuit Judge.

A jury found defendant Phoeun Lang (“Lang”) guilty of making false statements and applying for naturalization in violation of 18 U.S.C. §§ 1001(a)(2) and 1425(b). On appeal, Lang makes the following three arguments: (1) the admission of immigration form N-445 violated his Sixth Amendment right to confrontation, (2) the admission of immigration form N-445 under the public records exception to hearsay was error, 1 and (3) the government’s repeated reference to his prior conviction was unfairly prejudicial. Discerning no error, we affirm.

1. BACKGROUND

Accompanied by his…