## Facts

- Three Syrian-born brothers (Mowafak, Antoun, and Fadi Chahla) were prosecuted for using allegedly fraudulent marriages to U.S. citizens to obtain immigration benefits and later citizenship.
- The government alleged the brothers entered sham marriages with three women who were related or closely connected (including two sisters), supporting an inference of coordination.
- Evidence as summarized on appeal included indicia of non-bona fide marriages, such as lack of cohabitation, continued romantic relationships with others, and immigration paperwork and interviews tied to the marriages.
- One example involved Mowafak requesting that a U.S. citizen customer marry him to help with immigration problems; the couple allegedly did not live together and she maintained another relationship while sponsoring his immigration filings.
- A jury in the Middle District of Florida convicted each brother of:
  - Conspiracy under 18 U.S.C. § 371 (with objects involving false statements and marriage fraud), and
  - Two counts of unlawful procurement of citizenship under 18 U.S.C. § 1425(a).
- The defendants appealed, challenging sufficiency of the evidence, refusal of requested defense instructions, and denial of a mistrial.

## Issues

1. Whether sufficient evidence supported a single overarching § 371 conspiracy, rather than multiple separate conspiracies tied to individual marriages.
2. Whether sufficient evidence supported the § 1425(a) convictions, including whether misrepresentations about the marriages were material to naturalization.
3. Whether the district court reversibly erred by declining to give requested theory-of-defense jury instructions.
4. Whether the district court abused its discretion in denying a motion for mistrial based on allegedly prejudicial trial events.

## Decision

- The Eleventh Circuit affirmed all convictions.
- The court held the evidence was sufficient for a rational jury to find one overarching agreement to use fraudulent marriages to secure immigration benefits, considering a common goal and overlap of participants.
- The court held the § 1425(a) convictions were supported by sufficient evidence, including materiality, because fraud concerning marital bona fides could render lawful permanent residence unlawful and thereby make subsequent naturalization “contrary to law.”
- The court found no reversible instructional error because the given conspiracy instructions adequately conveyed that conviction required finding the single charged conspiracy and that multiple conspiracies would not suffice.
- The court found no abuse of discretion in denying a mistrial, concluding any potential prejudice was cured or insufficient to warrant that remedy.

## Legal Principles

- On sufficiency review after conviction, appellate courts view the evidence in the light most favorable to the government and ask whether a rational jury could find guilt beyond a reasonable doubt.
- A single conspiracy may be inferred from a common objective, the nature of the scheme, and overlapping participants; proof of multiple conspiracies does not satisfy a charge alleging one conspiracy.
- For 18 U.S.C. § 1425(a), misrepresentations are material if they have a natural tendency to influence immigration decisionmaking; fraud affecting the lawfulness of permanent residence can support a finding that later naturalization was procured “contrary to law.”
- A defendant is not entitled to particular theory-of-defense wording if the instructions given correctly state the law and substantially cover the defense theory.
- Denial of a mistrial is reviewed for abuse of discretion; relief requires substantial prejudice that is not adequately addressed by limiting instructions or the trial context.

## Conclusion

The Eleventh Circuit upheld convictions arising from an alleged marriage-fraud scheme, concluding the evidence supported a single conspiracy and material misrepresentations sufficient for § 1425(a), and finding no reversible error in the jury instructions or the refusal to declare a mistrial.


United States v. Chahla, 752 F.3d 939 (11th Cir. 2014)