Saturday, May 14, 2011

USE OF FRAUDULENT PASSPORT CAN BE EVIDENCE OF LACK OF REHABILITATION

In general terms, very few , if any, individuals are charged under Section 133 of IRPA with the use of a fraudulent document to enter Canada if they make a refugee claim.The provision is drafted in such a manner that it encourages the use of fraudulent and forged passports to enter Canada to make a claim, constituting an open invitation to human smugglers to exploit the loophole. In this day and age of heightened security concerns, this is nothing short of laughable.


Note that in the case below, the applicant managed to string things along for close to 19 years, an unprecedented period of time, while he sought various, creative ways to remain in Canada despite his previous criminal conviction in the US. Needless to say, the lengthy legal battle imposed a substantial cost on the system, which could have been diverted to deal with more meritorious cases.




Lasisi v. Canada (Minister of Citizenship and Immigration)

Between

Lafisu Eji Lasisi, Applicant, and

The Minister of Citizenship and Immigration, Respondent

[2011] F.C.J. No. 613

2011 FC 495

Docket IMM-1848-10

Federal Court

Montréal, Quebec

Tremblay-Lamer J.

Heard: April 21, 2011.

Judgment: April 27, 2011.

(26 paras.)

REASONS FOR JUDGMENT AND JUDGMENT

1 TREMBLAY-LAMER J.
:-- This is an application for judicial review, pursuant to subsection 72(1) of the
Immigration and Refugee Protection Act, SC 2001, c 27 (IRPA), of a decision of the Director
 General of the Case Management Branch at Citizenship and

Immigration Canada (the Minister's delegate), dated December 7,

2009, whereby the Minister's delegate denied an application

submitted by Lafisu Eji Lasisi (the applicant) for criminal

rehabilitation under paragraph 36(3)(c) of the IRPA.

I. BACKGROUND

2 The applicant, a citizen of Nigeria, first came to Canada as

a visitor in 1992. Although he submitted a claim for refugee status

at that time, it was subsequently declared abandoned. The applicant

was directed to appear, in September of 1994, at an inquiry that

would consider,
inter alia, his use of false identity documents.

The applicant failed to appear and in April of 1995 an immigration

warrant was issued for his arrest.

3
At some point in 1993, the applicant had left Canada for the

United States of America (USA). On June 2, 1995, he was convicted

in the US of Possession of a Fraudulent ID Card in contravention of

Illinois state law and was sentenced to 18 months probation. In

November of 2002, the applicant returned to Nigeria where he lived

until October 2006.

4
On October 2, 2006, the applicant returned to Canada, using

fraudulent identity documents to enter the country. He submitted

another refugee claim, but it was eventually rejected as he was

deemed ineligible to submit a further claim. A deportation order

was issued against the applicant in February of 2007. He submitted

a Pre-Removal Risk Assessment application, which was also rejected

in March of 2008.

5
On June 20, 2007, approximately a month after marrying a

Canadian citizen, the applicant submitted an application for

permanent residence as a member of the spouse or common-law partner

in Canada class, as well as an application for criminal

rehabilitation in respect of the US fraudulent ID offence. With








Page 5

respect to his application for criminal rehabilitation, the

applicant indicated, in part:

I believe I am rehabilitated because it's been well

over 10 years. I have not re-offended or been involved

in any activity that is illegal... I feel ashamed and

remorseful for these offences, and have learnt my

lesson.

6
On May 28, 2009, an analyst at the Case Management Branch at

Citizenship and Immigration Canada (CIC) prepared a rehabilitation

assessment recommending a negative determination with regards to

the application for criminal rehabilitation (the rehabilitation

assessment). The assessment indicated that the applicant's

conviction in the US rendered him inadmissible to Canada due to

serious criminality under paragraph 36(1)(
b) of the IRPA because

the US offence was equivalent to "Personation with intent to gain

advantage for himself, pursuant to section 403(
a) of the Criminal

Code of Canada."

7
The analyst indicated that CIC officials were, "not satisfied

that [the applicant] would not re-offend in a similar manner if

placed in a situation of need." Although it was noted that the

applicant had stated the he had learnt from the US conviction and

now understood the consequences more fully, the analyst found that

the applicant had, nonetheless, re-offended in a similar manner by

using false documents to enter Canada in 2006.

8
The rehabilitation assessment was sent to the applicant for

comment on August 24, 2009 and the applicant responded with

submissions on October 30, 2009.

II. THE DECISION UNDER REVIEW

9
On December 7, 2009, the Minister's delegate decided not to

grant the application for criminal rehabilitation under paragraph

36(3)(
c) of the IRPA. This decision was communicated to the

applicant via a letter dated March 18, 2010. The applicant

requested reasons which were sent on June 24, 2010. They consisted

of the text of the rehabilitation assessment that had been sent to

the applicant for comment in August of 2009, coupled with the

following hand-written note which was dated December 7, 2009 and

signed by the Minister's delegate:

Subject has a history of purposely using false

documentation. Most recently was in 2006 when he used








Page 6

a false passport to enter Canada. It can be argued

that a person has not committed a criminal offense by

using a false document to enter Canada for purposes of

making a refugee claim. However subject was deemed

ineligible for making a claim and therefore

demonstrated continued criminal behaviour in using

false documentation.

I am not satisfied the subject has sufficiently

demonstrated evidence of being re-habilitated.

III. ISSUES

10
The applicant raises three issues for consideration by this

Court:

a) Did the Minister's delegate breach the duty of

procedural fairness owed to the applicant by

making an alteration to the rehabilitation

assessment?

b) Did the Minister's delegate err by providing

inadequate reasons?

c) Was the decision not to grant the applicant's

request for criminal rehabilitation otherwise

unreasonable?

IV. LEGISLATIVE BACKGROUND

11
Paragraph 36(1)(b) of the IRPA indicates that a permanent

resident or foreign national is inadmissible on grounds of serious

criminality if they have been convicted of an offence outside of

Canada that, if committed in Canada, would constitute an offence

under an Act of Parliament punishable by a maximum term of at least

10 years:

Serious criminality

36. (1) A permanent resident or a foreign national is

inadmissible on grounds of serious criminality for

...

(
b) having been convicted of an offence outside

Canada that, if committed in Canada, would

constitute an offence under an Act of Parliament








Page 7

punishable by a maximum term of imprisonment of at

least 10 years; or

...

* * *

Grande criminalité 36. (1) Emportent interdiction de

territoire pour grande criminalité les faits suivants

:

[...]








b

) être déclaré coupable, à l'extérieur du Canada,

d'une infraction qui, commise au Canada,

constituerait une infraction à une loi fédérale

punissable d'un emprisonnement maximal d'au moins

dix ans;

[...]

12
However, paragraph 36(3)(c) of the IRPA indicates, in part,

that inadmissibility does not result from the circumstances set out

in paragraph 36(1)(
b) if, after the prescribed period (five years),

the permanent resident or foreign national satisfies the Minister

that they have been rehabilitated:

Application

36(3) The following provisions govern subsections (1)

and (2):

...

(
c) the matters referred to in paragraphs (1)(b)

and (
c) and (2)(b) and (c) do not constitute

inadmissibility in respect of a permanent resident

or foreign national who, after the prescribed

period, satisfies the Minister that they have been

rehabilitated or who is a member of a prescribed

class that is deemed to have been rehabilitated;








Page 8

...

* * *

Application 36(3)

Les dispositions suivantes régissent l'application des

paragraphes (1) et (2) :

[...]








c

) les faits visés aux alinéas (1)b) ou c) et

(2)
b) ou c) n'emportent pas interdiction de

territoire pour le résident permanent ou

l'étranger qui, à l'expiration du délai

réglementaire, convainc le ministre de sa réadaptation

ou qui appartient à une catégorie réglementaire de

personnes présumées réadaptées;

[...]

V. ANALYSIS

a)
Did the Minister's delegate breach the duty of








procedural fairness owed to the applicant by making an

alteration to the rehabilitation assessment?

13
The applicant submits that the Minister's delegate engaged

in "sharp practice" by making an alteration to the text of the

rehabilitation assessment relied upon in his reasons.

14
The impugned alteration is found at the beginning of the

assessment where the CIC analyst outlined the applicant's

immigration history. After indicating that the applicant had

arrived in Canada as a visitor in 1992 and had, in 1993, been

directed to appear at an inquiry regarding, among other things, the

use of false identity documents, the analyst wrote, "Failed to

appear for Inquiry in September 200 4 and an immigration warrant

for arrest was issued in April 1995" [emphasis added]. In the

version of the assessment included in the reasons provided by the

Minister's delegate, the "200" was crossed out, and a "199" was








Page 9

written in so that the sentence effectively read, "Failed to appear

for Inquiry in September 199 4 and an immigration warrant for

arrest was issued in April 1995" [emphasis added].

15
The applicant argues that this alteration materially changed

the rehabilitation assessment as compared to the version that was

provided for comment and response. He submits that this change

constitutes unfair and unjust "sharp practice" because the

implausibility of the applicant not appearing at an inquiry in

September 2004 when the arrest warrant in relation to that

non-appearance was issued nine years earlier, was one of the points

relied upon by the applicant in his rebuttal submissions.

16
There is no merit to this argument. It is clear that the

"2004" appearing in the original rehabilitation assessment was a

typographical error. The CIC analyst undoubtedly meant to indicate

that the applicant did not appear for the inquiry in September of

1994, not 2004. It seems quite unlikely, indeed, that the CIC

analyst would have been under the impression that an arrest

warrant, issued as it was in April 1995, would have been issued

nine years in advance of the event that triggered it - i.e. nine

years before the failure to appear. If anything, the alteration

reveals that the Minister's delegate attentively reviewed the

analyst's submissions and considered the applicant's response.

b)
Did the Minister's delegate err by providing








inadequate reasons?

17
The applicant argues that the reasons provided by the

Minister's delegate are inadequate. He submits that the handwritten

portion of the reasons were "illegible and very difficult to make

out any meaning at all". This contention is also without merit.

Although typewritten reasons may have been preferable, it is not

difficult to read and understand the delegate's handwriting in this

case.

18
Furthermore, as the respondent points out, the applicant

does not indicate having made any request to obtain a typed version

of the reasons. In this regard, I adopt the words of Justice Edmond

Blanchard from the
Hayama v Canada (Minister of Citizenship and








Immigration)

, 2003 FC 1305, [2003] FCJ No 1642, at para 15 of the

decision:

... If the applicant was unsatisfied with the decision

letter and felt it did not adequately explain the

decision, a request should have been made for further








Page 10

elucidation. There is no evidence that such a request

would have been refused. ...

19
I find that the delegate's reasons are adequate. The "four

fundamental purposes" for the provision of reasons set out by the

Federal Court of Appeal in
Vancouver International Airport








Authority v Public Service Alliance of Canada

, 2010 FCA 158, [

2010] FCJ No 809, at para 16, are met. It is clear why the

Minister's delegate decided the way that he did. Sufficient details

were provided so that the applicant could decide whether or not to

apply for judicial review, and so that this Court can assess

whether the decision falls within a range of possible acceptable

outcomes. The reasons provided are justified, intelligible and

display a discernable rationality and logic.

c)
Was the decision not to grant the applicant's request








for criminal rehabilitation otherwise unreasonable?

20
The applicant submits that the delegate's ultimate decision

is unreasonable because it is based on the erroneous determination

that the applicant's use of false identity documents to re-enter

Canada in 2006 constituted "criminal behaviour". The CIC analyst,

in the rehabilitation assessment relied upon by the Minister's

delegate, indicated that the applicant "broke the law" when he

re-entered Canada in 2006 using a fraudulent passport. The

Minister's delegate agreed with this conclusion and explained in

his handwritten reasons that the applicant's use of fraudulent

documentation in 2006 amounted to "criminal behaviour".

21
The applicant contends that section 133 of the IRPA

expressly exempts refugees from prosecution for using false

documents to enter the country. Thus, the applicant submits the

fact that he re-entered the country in 2006 via "improper means"

could not properly be considered a violation of Canadian law, nor

could it amount to "criminal behaviour".

22
The question of whether the Minister's delegate erred in

exercising his discretion under paragraph 36(3)(
c) of the IRPA is a

question that must be reviewed against the reasonableness standard.

23
Section 133 of the Immigration and Refugee Protection Act

reads as follows:

Deferral 133. A person who has claimed refugee

protection, and who came to Canada directly or

indirectly from the country in respect of which the








Page 11

claim is made, may not be charged with an offence

under section 122, paragraph 124(1)(
a) or section 127

of this Act or under section 57, paragraph 340(
c) or

section 354, 366, 368, 374 or 403 of the Criminal

Code, in relation to the coming into Canada of the

person, pending disposition of their claim for refugee

protection or if refugee protection is conferred.

* * *

Immunité 133. L'auteur d'une demande d'asile ne peut,

tant qu'il n'est statué sur sa demande, ni une fois

que l'asile lui est conféré, être accusé d'une

infraction visée à l'article 122, à l'alinéa 124(1)
a)

ou à l'article 127 de la présente loi et à l'article

57, à l'alinéa 340
c) ou aux articles 354, 366, 368,

374 ou 403 du Code criminel, dès lors qu'il est arrivé

directement ou indirectement au Canada du pays duquel

il cherche à être protégé et à la condition que

l'infraction ait été commise à l'égard de son arrivée

au Canada.

24
Justice Carolyn Layden-Stevenson in Uppal v Canada (Minister








of Citizenship and Immigration)

, 2006 FC 338, [2006] FCJ No 455, at

para 21, indicated that section 133 of the IRPA is intended, "to

allow
bona fide refugees and refugee claimants to use false

passports and supporting documents obtained by them for the purpose

of making their way into Canada and to shelter them from a finding

of inadmissibility for holding and using those documents." The

Minister's delegate was right to point out that the applicant was

not a
bona fide refugee. Section 133 indicates that a person may

not be charged with offences relating to fraudulent identification,

"pending disposition of their claim for refugee protection or if

refugee protection is conferred." There is no pending refugee claim

in the applicant's case and refugee protection has not been

conferred. As such, section 133 of the IRPA does not apply. In any

event, section 133 of the IRPA only prevents charging an individual

with an offence, it does not legalize the use of false

identification.

25
Indeed, the applicant did violate Canadian law when he

entered the country in 2006 by means of fraudulent identification.

Indeed, this was evidence of continued criminal behaviour similar

to the criminal behaviour in respect of which the applicant claims

to be rehabilitated. As such, I can not find that the delegate's

determination that the applicant had not "sufficiently demonstrated








Page 12

evidence of having re-habilitated" falls outside the range of

possible, acceptable outcomes which are defensible in respect of

the facts and law. The delegate's decision was not unreasonable.

26
For the foregoing reasons, the application for judicial

review will be dismissed.

JUDGMENT

THIS COURT'S JUDGMENT IS that
the application for judicial review








is dismissed.

TREMBLAY-LAMER J.

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