Supreme Court Case Summary

Flores-Figueroa v. United States

Case Summary

Flores-Figueroa v. U.S. May 4th 2009

Ignacio Flores-Figueroa  v. U.S. (04 May, 2009), United States Supreme Court: online http://ashford.blackboard.com/webapps/portal/frameset.jsp?tab_id=_2_1&url=%... last accessed 05  May 2009.

Flores-Figueroa (Petitioner - Mexican National) v. U.S. (Respondent - United States Government)

Procedural History

•          Flores-Figueroa secured employment with a fake name and social security card belonging to someone else.

•          Flores-Figueroa was reported to U.S. Immigration and Customs Enforcement for false documents.

•          Flores-Figueroa pleaded guilty to entering the country illegally and to using a false document, but pleaded not guilty to aggravated identity theft.

•          The U.S. District Court for the Southern District of Iowa found Flores-Figueroa guilty of two counts of aggravated identity theft.

•          Flores-Figueroa was sentenced to 51 months incarceration for the misuse of immigration documents and entry without inspection and a consecutive 24 months for the two counts of aggravated identity theft.

•          Flores-Figueroa appeals the conviction on the basis that 18 U.S.C. § 1028A(a)(1) states that an individual must know that the identification used belonged to another person.

•          In April 2008 the conviction was upheld by the U.S. Court of Appeals for the 8th Circuit.

•          The case was accepted for review by the U.S. Supreme Court on October 20th 2008.

Issue

Can a person who uses a false means of identification without knowledge that the identification belonged to another person be convicted of aggravated identity theft under 18 U.S.C. 1028A(a)(1)?

Facts

•          In 2000 the plaintiff secured employment using a false name, social security number, and resident alien card.

•          In 2006 the plaintiff attempted to begin working under his own name by supplying his employer with a social security card and permanent resident alien card in his own name.

•          The newly provided documents were forgeries and the employer informed U.S. Immigration and Customs Enforcement.

•          Flores-Figueroa pleaded guilty to entering the country illegally and to using a false document, but pleaded not guilty to aggravated identity theft.

•          Flores-Figueroa stated that he did not know that real people used social security numbers during his trial.

•          The U.S. District Court for the Southern District of Iowa found Flores-Figueroa guilty of two counts of aggravated identity theft.

•          Flores-Figueroa appealed the conviction on the basis that 18 U.S.C. § 1028A(a)(1) states that an individual must know that the identification used belonged to another person. Flores-Figueroa insisted that the government must prove that he had knowledge that the identification belonged to someone else in order to convict him.

•          In April 2008 the conviction was upheld by the U.S. Court of Appeals for the 8th Circuit.

•          The case was reviewed and the decision was unanimously reversed and remanded by the U.S. Supreme Court on May 4th, 2009.

Rule of Law

1.          An individual cannot be convicted of aggravated identity theft unless the government can prove that the individual had knowledge that the means of identification they were using belonged to another person.

Reasoning

•          Supreme Court finds that strong textual language does not justify heavily penalizing an individual who may have had no knowledge of what they possessed.

•          Flores-Figueroa cannot be convicted of aggravated identity theft because it was not proven by the government that he had knowledge that the identification he was using belonged to someone else.

•          An individual must also know that the something they are using is a piece of identification.

Holding

Court reverses decision of lower court in favor of the petitioner, Ignacio Flores-Figueroa, because the government failed to prove that Flores-Figueroa had knowledge that the identification he was using belonged to someone else.

This decision was a unanimous 9-0 vote in the Supreme Court. The majority opinion was delivered by Justice Stephen G. Breyer. Opinions concurring in part and in the judgment were filed by Justice Antonin Scalia, Justice Clarence Thomas, and Justice Samuel A. Alito.

This decision further clarifies 18 U.S.C. 1028A(a)(1) and its legal application in aggravated identity theft cases by upholding the necessity of actual knowledge on the part of the defendant. This knowledge must be proven to exist by the government for a legal conviction.























References

Ignacio Flores-Figueroa  v. U.S. (04 May, 2009), United States Supreme Court: online http://ashford.blackboard.com/webapps/portal/frameset.jsp?tab_id=_2_1&url=%... last accessed 05  May 2009.

The Oyez Project, Flores-Figueroa v. United States U.S. ___

available at: (http://oyez.org/cases/2000-2009/2008/2008_08_108)

(last visited Tuesday, May 5, 2009).