United States v. Young

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A jury convicted Young of attempting to provide material support to the Islamic State of Iraq and the Levant (ISIL), a designated foreign terrorist organization, 18 U.S.C. 2339B, and two counts of attempting to obstruct justice, 18 U.S.C. 1512(c)(2). The Fourth Circuit affirmed the material support conviction, vacated the obstruction convictions, and remanded for resentencing. The court upheld the district court’s admission of the Nazi and white supremacist paraphernalia found during a search of Young’s home; the rejection of an entrapment defense; various evidentiary rulings; and the certification of an expert witness on militant Islamist and Nazi “convergence.” The evidence was insufficient to prove the nexus and foreseeability requirements of the obstruction statute; the government was required to prove Young “corruptly” attempted to “obstruct[], influence[], or impede[]” “an official proceeding. In neither specified situation in which Young made statements to the FBI or to others was Young’s conduct connected to a specific official proceeding, nor was such a specific official proceeding reasonably foreseeable to Young. View "United States v. Young" on Justia Law