US v. Madrigal-Valadez: Madrigal-Valadez was convicted after a bench trial of entering a military installation, Fort Lee in Virginia, for a purpose prohibited by law. That purpose, allegedly, was being an alien in the United States illegally. The conviction arose from an incident in which Madrigal-Valadez drove a soldier back to Fort Lee. When his vehicle was stopped to be checked out prior to entry, Madrigal-Valadez could not present the proper identification needed to satisfy Fort Lee's entry requirements. He was arrested at that time.
On appeal, the Fourth Circuit reversed Madrigal-Valadez's conviction. Addressing an issue not before resolved in this circuit, the court concluded, in line with several other circuits, that before a person can be convicted of this trespass offense he must be provided notice that entry onto the military property is prohibited. Although there was a sign on the road to the gate that provided some notice (albeit in English, which Madrigal-Valadez didn't speak), it was not sufficient because once someone turned onto that road they were already on the base. Thus, Madrigal-Valadez's conviction could not stand. The court also rejected the district court's conclusion that Madrigal-Valadez's illegal immigration status could constitute a "purpose prohibited by law" for which he entered the base.
Congrats to the Defender office in the EDVa on the win!