Ashraf v. Lynch, ___ F.3d ___, 2016 WL 1612766 (8th Cir. Apr. 22, 2016) (federal crime of conspiracy to commit marriage fraud was complete, in violation of 18 U.S.C. 371 and 8 U.S.C. 1325(c), and thus five-year statute of limitations began to run, on date that alien submitted petition to remove conditions on residence, as the last overt act in furtherance of the conspiracy); United States v. Stewart, 744 F.3d 17, 18, 23 (1st Cir. 2014; United States v. Bennett, 765 F.3d, 887, 895 (8th Cir. 2014) (conspiracy is a continuing offense that continues through the last overt act committed in furtherance of the conspiracy); United States v. Farmer, 73 F.3d 836, 841 (8th Cir. 1996); United States v. Garfinkel, 29 F.3d 1253, 1259"60 (8th Cir. 1994); distinguishing United States v. Rojas, 718 F.3d 1317, 1320 (11th Cir. 2013) (the crime of marriage fraud, under 8 U.S.C. 1325(c), is completed on the date the parties enter into the marriage).

 

TRANSLATE