present a defense,” has little merit. See, e.g., United States v. Lyon, 397 F.2d 505, 513 (7th Cir.1968) (permitting judicial notice of laws in the criminal context). Hemphill’s conviction did not depend on the fictitious legal citations in the deeds. The government presented to the jury copies of letters that Hemphill sent to banks and property owners, including Atlas Oil, claiming that their properties had been seized and he had taken title as a “receiver” for the federal government. In light of these letters, and the other evidence of his fraudulent scheme, we are confident that absent the judicially noticed facts, the prosecution’s case would not have been significantly less persuasive in the mind of the average juror. See United States v. Cooper, 591 F.3d 582, 590 (7th Cir.2010) (<HOLDING>). So, even if it we assume that the district
recognizing that the declaratory judgment act is only procedural and does not create substantive rights internal quotation marks and citations omitted holding that apprendi error is harmless if the court finds beyond a reasonable doubt that the result would have been the same absent the error internal quotation marks and citation omitted holding that state officials cannot have been expected to predict the future course of constitutional law internal quotation marks omitted holding that the test for harmless error is whether in the mind of the average juror the prosecutions case would have been significantly less persuasive had the improper evidence been excluded citations and internal quotation marks omitted holding that an error is harmless if it was inconsequential to the ultimate nondisability determination internal quotation marks omitted