nationalsecuritylaw United States v. Kassar (2d Cir. Sep. 21, 2011)

September 25, 2011

* United States v. Kassar (2d Cir. Sep. 21, 2011)

A Second Circuit panel has affirmed the conviction of three defendants who were convicted on charges stemming from a sting operation involving a faux effort by the FARC to obtain weapons for use against U.S. personnel. It’s a fascinating fact pattern. As for the issues treated in the opinion, the include the expected reviews of the sufficiency of the evidence, a rejection of a constitutional challenge to the material support statute (relying on HLP v. Holder), and rejection of the argument that 18 USC 1114 and 1117 don’t apply extraterritorially, among other things. Nothing terribly novel, I think, but all quite interesting to read.