United States v. Orellana-Blanco

Santos Orellana-Blanco (defendant) was prosecuted for a sham marriage to Beatrice Boehm and for lying to immigration officials about it; at trial, Orellana testified he had an intimate relationship with Boehm before the wedding and that the marriage failed for financial reasons, while Boehm testified she met him only on their wedding day and considered it a sham from the start. The district court admitted a report of Orellana's immigration interview, prepared by an officer named Kendall who was on sick leave and did not testify; a different officer who only briefly assisted with translation testified instead, admitting the report wasn't verbatim and that he couldn't fully decipher Kendall's cryptic notes. The jury convicted Orellana despite apparent reservations about Boehm's credibility, and he appealed the report's admission.