A former leader of a Haitian paramilitary force failed to persuade a judge that his mortgage fraud conviction in the United States was unsound.

Eastern District Judge Jack Weinstein denied Emmanuel “Toto” Constant’s habeas corpus petition on Friday, saying the lead-up to his conviction—which involved a state judge’s sua sponte decision to vacate Constant’s plea deal in light of serious allegations against him for his acts in Haiti—did not run afoul of due process requirements.

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