Gilda Altagracia Abreu-Reyes, A.K.A. Gilda A. Desmith v. Immigration and Naturalization Service

PAEZ, Circuit Judge,

dissenting.

I respectfully dissent. I cannot agree with the majority’s conclusion that the pre-sentence report was admissible in Abreu-Reyes’s removal hearing to determine the tax loss to the government. There is no evidence that the INS sought release of Abreu-Reyes’s presentence report from the district court for which it was prepared as it was required to do by United States v. Schlette, 842 F.2d 1574 (9th Cir.), amended, 854 F.2d 359 (9th Cir.1988). Additionally, it is unclear whether the dis*1035trict court adopted the tax loss reflected in the presentence report in determining Abreu-Reyes’s sentence under the U.S. Sentencing Guidelines Manual (“Sentencing Guidelines”). Due to this uncertainty, it was fundamentally unfair to admit the report into evidence and to rely on it to order Abreu-Reyes’s removal.

Even assuming that the Immigration Judge (“IJ”) properly considered the pre-sentence report, Abreu-Reyes was not removable as an aggravated felon because she did not commit an offense that “involves fraud or deceit in which the loss to the victim or victims exceeds $10,000.” 8 U.S.C. § 1101(a)(43)(M)(i). A conviction for filing a false tax return cannot be subsumed under the “fraud or deceit” provision because Congress intended for only one tax offense — tax evasion — and only when the loss to the government exceeds $10,000, to constitute an aggravated felony. 8 U.S.C. § 1101(a)(43)(M)(ii).

1. Admission of the Presentence Report

Presentence reports contain background information about a defendant, including the defendant’s criminal record and other information relevant to sentencing and treatment, as well as details about the circumstances of the offense and the victims of the offense. Fed.R.Crim.P. 32(b)(4); Julian v. United States Dep’t of Justice, 806 F.2d 1411, 1414 (9th Cir.1986) (“Julian I”), aff'd, 486 U.S. 1, 108 S.Ct. 1606, 100 L.Ed.2d 1 (1988). Today presen-fence reports serve two fundamental purposes: (1) district courts use them to determine a defendant’s sentence, see Fed. R.Crim.P. 32, and (2) the Bureau of Prisons relies on them to classify prisoners, to determine ■ eligibility for treatment programs, and to assess eligibility for privileges while in custody. United States Dep’t of Justice v. Julian, 486 U.S. 1, 3, 5, 108 S.Ct. 1606, 100 L.Ed.2d 1 (1988) UJul-ian II”); Julian I, 806 F.2d at 1415.1

If a third party such as the INS wants to use a presentence report for another purpose, it must seek release of the report from the district court for which it was prepared. See Schlette, 842 F.2d at 1581. In Schlette, as the majority notes, we held that when a third party requests that a district court release a presentence report, the third party must establish that disclosure will “serve the ends of justice.” Id. at 1579, 1581; see also Julian II, 486 U.S. at 12, 108 S.Ct. 1606 (noting that courts generally require “some showing of special need before they will allow a third party to obtain a copy of a presentence report”). The district court must then weigh the need for disclosure against the need for confidentiality. Schlette, 842 F.2d at 1581.

The majority holds that the IJ properly relied on Abreu-Reyes’s presentence report because the determination of whether an alien has committed an aggravated felony meets Schlette’s “ends of justice” standard. Maj. op. at 1033-34. Whether the “ends of justice” standard has been met, however, is a determination that should be *1036made initially by the district court familiar with the underlying criminal proceeding. Although requesting the district court to release an alien’s presentence report may be a burden for the INS, it is dh important step in preserving confidential information and ensuring the reliability of thé report.2 If the district court were to order that thé presentence report be released, then it must redact any information that it determines is confidential pursuant to Rule 32(b)(5) of the Federal Rules of Criminal Procedure.3 See id. at 1585 (remanding to the district court to redact confidential information). The court would also have the opportunity to redact erroneous or unreliable information so that use of the report other than for sentencing or prison classification would serve the “ends of justice.”

There is no evidence in the administrative record here that the INS filed a motion in the district court to obtain a copy of Abreu-Reyes’s presentenee report. Cf. United States v. Villa, 701 F.Supp. 760, 761-62 (D.Nev.1988) (releasing a presen-tence report to the INS for use in a deportation proceeding). Without the benefit of the district court’s ruling ordering disclosure of the report, we cannot be certain that the report does not contain confidential, erroneous, or unreliable information. Because the INS did not adhere to Schlette’s mandate,, it was fundamentally unfair for the immigration judge to admit the report into evidence. See Baliza v. INS, 709 F.2d 1231, 1233 (9th Cir.1983) (holding that the standard for admissibility of hearsay evidence in administrative proceedings is whether it is “probative and whether its admission [i]s fundamentally fair”).

It was also fundamentally unfair to admit the report into evidence because it is unclear from the administrative record whether the district court relied on the tax loss reflected in the presentence report. The IJ stated that, in sentencing Abreu-Reyes, the district court apparently relied on the presentence report’s conclusion that the tax loss to the government was $37,546. A review of the presentence report and Abreu-Reyes’s sentence, however, demonstrates that there is insufficient information in the administrative record to ascertain whether the sentencing court adopted an amount in excess of $10,000 as the tax loss in determining Abreu-Reyes’s sentence.

The presentence report recommended a base offense level of 12, based on a tax loss between $23,500 and $40,000 under the Sentencing Guidelines in effect at the time of Abreu-Reyes’s sentence. U.S. Sentencing Guidelines Manual § 2T4.1 (2000). The report also recommended a Specific Offense Characteristic upward adjustment of 2 levels and a downward adjustment for Acceptance of Responsibility of 2 levels. Thus, the suggested total offense level was 12. According to the Sentencing Table, this offense level corresponded to a 10-16 month sentence. Id. ch. 5, pt. A.

*1037Abreu-Reyes, however, received only a six-month sentence. The greatest offense level that corresponded to a six-month sentence was offense level 10. Id. We cannot tell from the administrative record just how the district court arrived at this sentence. The district court could have determined that the tax loss was in fact lower than that estimated in the pre-sentence report, and perhaps even under $10,000. Fixing the tax loss between $8,000 and $13,500, the base offense level would have been 10, not 12. With a base offense level of 10, the final offense level would have corresponded to a sentencing range of 6-10 months.

Alternatively, the district court could have departed downward 2 levels to reach the lower sentence or could have considered the plea agreement, referenced by the majority, which apparently did not contemplate the Specific Offense Characteristic upward adjustment of 2 levels. Without the transcript of the sentencing hearing, we have no basis for discerning how the district court arrived at Abreu-Reyes’s six-month sentence and, more importantly, whether the district court concluded that the tax loss to the government was greater than $10,000.4

This uncertainty, and its drastic consequences for Abreu-Reyes in this case, is precisely why we established the rule in Schlette dictating that a third party, such as the INS, must obtain release of a pre-sentence report from the district court before it can use the report in . another proceeding, The IJ should have sustained Abreu-Reyes’s objection to the presen-tence report as hearsay.5

2. Aggravated Felony

Even assuming that the presentence report was properly admitted into evidence, Abreu-Reyes is still not removable because she did not,commit an aggravated felony. Congress has defined an aggravated felony in pertinent part as:

(M) an offense that—
(i) involves fraud or deceit in which the loss to the victim or victims exceeds $10,000; or
(ii) is described in section 7201 of Title 26 (relating to tax evasion) in which the revenue loss to the Government exceeds $10,000[.]

8 U.S.C. § 1101(a)(43).

. That Congress included a separate statutory provision, for tax evasion demonstrates that it did not intend to include tax offenses within the “fraud or deceit” text. Rather, as the statute reflects, Congress drew a distinction between tax offenses and other crimes involving fraud and deceit. Congress then targeted only the more egregious act of tax evasion, and only when the loss to the government exceeds $10,000, as sufficiently serious to warrant removal. “The logic that invests the omis*1038sion with significance is familiar: the mention of some implies the exclusion of others not mentioned.... Expressio unius est ex-clusio alterius.” United Dominion Indus., Inc. v. United States, 532 U.S. 822, 836, 121 S.Ct. 1934, 150 L.Ed.2d 45 (2001) (internal quotation marks and citation omitted).

If Congress intended for tax crimes other than tax evasion to constitute aggravated felonies when the loss to the government exceeds $10,000, it could have easily defined an aggravated felony in 8 U.S.C. § 1101(a)(43)(M)(ii) as any “tax offense in which the revenue loss to the Government exceeds $10,000” or identified each relevant section of Title 26. Cf. United States v. Corona-Sanchez, 234 F.3d 449, 454 (9th Cir.2000) (reasoning that because Congress used the term “theft offense” rather than “theft” to define an aggravated felony and “expressly included the ‘receipt of stolen property’ under the definition of ‘theft offense,’ ... Congress intended to paint ‘theft offense’ with a broad brush”).

Thus, even assuming that the presen-tence report was admissible, Abreu-Reyes did not commit an aggravated felony. Accordingly, I would grant the petition.6

. Prior to the enactment of the Comprehensive Crime Control Act of 1984, Pub.L. 98-473, Tit. II, ch. 2, 98 Stat.1987, presentence reports were also routinely used to aid in parole determinations. Julian II, 486 U.S. at 5 n. 3, 108 S.Ct. 1606; Julian I, 806 F.3d at 1415.

The majority cites Schlette, 842 F.2d at 1581, for the proposition that “an ancillary function” of presentence reports "is to aid agency decision-making,” and therefore broadly encompasses. the INS's civil enforcement responsibilities. Maj. op. at 1033. The majority, however, takes this statement in Schlette, which cites Julian I, 806 F.2d at 1415, out of context. In Julian I, we were not discussing the use of a presentence report by any governmental agency. Instead, our discussion focused on the use of presentence reports by the district court, the Bureau of Prisons, and the Parole Commission. 806 F.2d at 1415.

. As an alternative to seeking release of a presentence report, the INS could obtain a copy of the transcript of a defendant’s sentencing hearing. The transcript would contain the district court’s factual and sentencing guideline determinations. See Fed.R.Crim.P. 32(c)(1); 18 U.S.C. § 3553(c).

. Rule 32(b)(5) provides:

The presentence report must exclude: (A) any diagnostic opinions that, if disclosed, might seriously disrupt a program of rehabilitation; (B) sources of information obtained upon a promise of confidentiality; or (C) any other information that, if disclosed, might result in harm, physical or otherwise, to the defendant or other persons.

These same confidential provisions were contained in subsection (c)(3)(A) of the previous version of Rule 32, which is cited in Schlette.

. Abreu-Reyes's sentence could not have been a combination of a six-month sentence plus either community confinement or home detention with supervised release, as the majority suggests. See U.S. Sentencing Guidelines Manual § 5Cl. 1(c)(2) (2000) (explaining that a Zone B minimum term of imprisonment may be satisfied by imprisonment plus supervised release with a condition of community confinement or home detention). This is because the Judgment and Probation/Commitment Order did not impose community confinement or home detention as a condition of supervised release.

. The majority contends that there is "no indication” that Abreu-Reyes filed written objections to the presentence report pursuant to Rule 32(b)(6)(B) of the Federal Rules of Criminal Procedure. Maj. op. at 1032-33. Without reviewing the district court record, we ■ cannot determine whether Abreu-Reyes's ■ criminal defense lawyer filed Rule 32(b)(6)(B) objections.

. Because I would grant the petition, I find it unnecessary to reach Abreu-Reyes's remaining arguments.