United States v. Innocent Nzamubereka, 666 F. App'x 327

Nzamubereka, a Rwandan citizen, had asylum revoked after an aggravated assault conviction and was subject to a final order of removal.
He was indicted and convicted by a jury for two counts of preventing or hampering his removal in violation of 8 U.S.C. § 1253(a)(1)(C).
Charges arose from two incidents where he refused to sign a transit visa application required for removal to Rwanda via South Africa.
Deportation officers testified they repeatedly warned him that failure to cooperate could lead to criminal prosecution and explained why his belief that he still had asylum was incorrect.
Nzamubereka argued his refusal was based on a reasonable, but mistaken, belief he still had asylum; he preserved a sufficiency-of-the-evidence challenge focused on mens rea.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Nzamubereka acted knowingly/willfully to prevent removal under § 1253(a)(1)(C)	Nzamubereka: he reasonably (though incorrectly) believed he still had asylum, so lacked required mens rea	Government: officers informed him his asylum was revoked and warned of prosecution; refusal to sign despite warnings supports knowing/willful conduct	Court: Affirmed — evidence was sufficient for a rational jury to find knowing and willful conduct

United States v. Ferguson, 211 F.3d 878 (5th Cir. 2000) (standard for reviewing sufficiency of the evidence)
United States v. Lankford, 196 F.3d 563 (5th Cir. 1999) (view evidence in light most favorable to verdict)
United States v. Castro, 15 F.3d 417 (5th Cir. 1994) (same sufficiency-of-evidence standard)
United States v. Diallo, [citation="569 F. App'x 221"] (5th Cir. 2014) (noting § 1253(a)(1)(C) requires proof of knowing prevention/hampering)
Heikkinen v. United States, 355 U.S. 273 (1958) (discussed regarding officials’ representations and mens rea)