Medunjanin v. United States, No. 21-1438 (2d Cir. 2024)
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Adis Medunjanin was arrested in 2010 and charged with nine terrorism-related counts, including attempting to commit an act of terrorism and possessing a destructive device in furtherance of crimes of violence. The charges stemmed from a plot to conduct coordinated suicide bombings in the New York City subway system. Medunjanin was convicted on all counts and sentenced to life imprisonment.
Medunjanin appealed his conviction, arguing that his convictions under 18 U.S.C. § 924(c) for possessing a destructive device in furtherance of crimes of violence should be vacated. He claimed that the crimes were predicated on invalid "crimes of violence" in light of a Supreme Court decision, Sessions v. Dimaya. The District Court agreed with the government that one of the § 924(c) convictions should be vacated, but upheld the other because it was predicated on attempted terrorism, which remained a crime of violence.
In the United States Court of Appeals for the Second Circuit, Medunjanin argued that the attempted terrorism count was an invalid predicate because the jury may have found him guilty of attempted terrorism based on aiding and abetting liability. The court disagreed, holding that the fact that a defendant may have been convicted of an otherwise valid crime of violence based on an aiding and abetting theory of liability has no effect on the crime’s validity as a § 924(c) predicate. The court affirmed the judgment of the District Court.
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