United States v. Sarwari, No. 10-4944

Decided Feb. 9, 2012

On behalf of his three stepsons, Ghulam Nabi Sarwari prepared, signed and submitted applications for United States passports and listed himself as the child’s father, when in fact, Sarwari is neither the birth father nor the adoptive father of any of the children. A jury convicted Sarwari of three counts of willfully and knowingly making a false statement on a passport application. Sarwari appealed. The Fourth Circuit affirmed, noting that the word “father” is not so “fundamentally ambiguous” that Sarwari’s answer could not provide the basis for a false statement conviction. Further, the Court held that the district court did not err in failing to instruct the jury regarding the lack of a statutory definition of the word “father.”

Full Opinion

-Sara I. Salehi

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