People v. Hassan

Ahmed Hassan (defendant) and Ana Deleon were married by a minister in a notary’s office in California in a confidential marriage. Under California law, a confidential marriage required that the parties must have already been living together as spouses prior to the marriage. The notary explained this requirement to Hassan and Deleon, had them sign the marriage license, and submitted the license to the county for recordation. United States Immigration and Customs Enforcement (ICE) suspected Hassan and Deleon of marriage fraud, in which a marriage is entered into to obtain a green card for one of the spouses. ICE began an investigation into the marriage. In the course of the investigation, Hassan and Deleon provided conflicting testimony and suspect evidence to federal ICE agents regarding the circumstances of their marriage and Hassan’s immigration status. Hassan provided several documents to ICE agents that later proved to be falsified, including a purported marriage document from a mosque and fraudulent immigration forms. Hassan was charged under California law with offering a false document for recordation for the state marriage license, and with offering false evidence for the fraudulent documents he submitted to the ICE agents. Hassan was convicted on both counts. He appealed his conviction for providing false evidence, alleging insufficient evidence existed to support the conviction.