9th Cir.

USA v. Sangbarani

July 13, 2026 ·2:22-cr-00360-AB ·Unpublished · By James Taylor

The Ninth Circuit affirmed the conviction of Arbi Setaghaian Sangbarani for drug distribution and money laundering. The court rejected multiple challenges regarding jury instructions, evidentiary rulings, and the Confrontation Clause.

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Background

Defendant Arbi Setaghaian Sangbarani appealed his jury conviction on several counts of drug distribution and money laundering. He challenged various district court rulings, including jury instructions on mere presence and deliberate ignorance, evidentiary decisions regarding a paralegal and Bitcoin deposits, and the exclusion of certain impeachment evidence against cooperating witnesses.

The court’s reasoning

The court reviewed jury instruction challenges for abuse of discretion or de novo, assuming de novo review applied. It found that any failure to instruct on cooperating witness benefits was harmless because the jury heard evidence of plea deals and the witness was thoroughly impeached. Regarding the Confrontation Clause, the court held that barring stale convictions and uncharged conduct was appropriate since the witness’s credibility was already attacked on other grounds. The court affirmed that a mere presence instruction is unnecessary when the government proves more than presence. It also upheld the exclusion of a paralegal’s summary chart as irrelevant and the admission of Bitcoin evidence as properly founded. Finally, the court found no constructive amendment to the indictment and rejected the cumulative error argument.

there is no reasonable possibility that the error materially affected the verdict

United States v. Pierre, 254 F.3d 872, 877 (9th Cir. 2001)

What it means going forward

The decision reinforces the Ninth Circuit’s standard for harmless error in jury instruction cases involving cooperating witnesses and clarifies the limits of impeachment evidence under the Confrontation Clause for stale convictions.