## Facts

- Beatrice Munyenyezi, a Rwandan national, entered the United States as a refugee and later became a lawful permanent resident and U.S. citizen.
- Federal prosecutors alleged she concealed her identity and activities during the 1994 Rwandan genocide in immigration and naturalization applications and interviews.
- The government’s theory was that she participated in or aided persecution by using a roadblock near her husband’s hotel to identify, detain, and target Tutsi civilians and others, and that she later denied those facts under oath.
- Witnesses from Rwanda testified about her presence, role, and conduct during the genocide period; the defense challenged credibility, memory, and identification.
- A jury convicted her of immigration-related fraud offenses and perjury based on false statements made in the refugee process and in subsequent proceedings.

## Issues

1. Whether the evidence was sufficient to prove beyond a reasonable doubt that Munyenyezi knowingly made material false statements in immigration/naturalization matters and committed perjury.
2. Whether alleged errors in admitting or excluding evidence, including impeachment and credibility-related material, required a new trial.
3. Whether the district court’s instructions and management of the trial (including limits on cross-examination and argument) violated constitutional or procedural rights.

## Decision

- The First Circuit affirmed the judgment of conviction.
- The court held that the trial evidence, viewed in the light most favorable to the verdict, permitted a rational jury to find the essential elements of the charged offenses.
- The court found no reversible evidentiary or instructional error and concluded that the district court acted within its discretion in managing the trial.
- Any identified missteps were deemed harmless in light of the full record and the strength of the government’s proof on the elements the jury had to decide.

## Legal Principles

- A conviction must be upheld on appeal if, viewing the evidence in the prosecution’s favor, a rational jury could find guilt beyond a reasonable doubt.
- For immigration and naturalization fraud, the government must prove a knowing false statement and materiality—i.e., the statement had a natural tendency to influence, or was capable of influencing, the relevant decision.
- For perjury, the government must prove the defendant knowingly made a false, material statement under oath; credibility disputes are for the jury.
- Trial courts have broad discretion over evidentiary rulings and reasonable limits on cross-examination; reversal generally requires both error and prejudice affecting substantial rights.
- Appellate review focuses on whether alleged trial errors, individually or cumulatively, undermined the fairness of the proceedings; harmless errors do not warrant a new trial.

## Conclusion

The First Circuit upheld Munyenyezi’s immigration fraud and perjury convictions, concluding that the jury had a sufficient evidentiary basis to find knowing, material falsehoods and that the challenged trial rulings did not warrant reversal.


United States v. Munyenyezi, 781 F.3d 532 (1st Cir. 2015)