Passport Fraud Convict Can’t Blame His Attorney

A criminal defense attorney didn’t have to follow his client’s novel interpretation of a passport fraud law in order to provide effective assistance, the U.S. Court of Appeals for the District of Columbia Circuit ruled Jan. 27 (United States v. Vyner, 2017 BL 24562, D.C. Cir., No. 14-3091, 1/27/17).

The attorney’s advice that the defendant plead guilty to passport fraud under 18 U.S.C. §1546(a) was reasonably competent, the decision by Judge Judith W. Rogers found.

The dispute centered on an open question in the D.C. Circuit: whether the statute covers foreign passports.

The D.C. Circuit didn’t answer ...