Petition for Writ of Certiorari — Mirsad Ramic, Petitioner v. United States

Supreme Court briefAug 18, 2026

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No. 26-____________

IN THE SUPREME COURT OF THE UNITED STATES

MIRSAD RAMIC

PETITIONER,

UNITED STATES OF AMERICA,

RESPONDENT.

______________________________________________________

ON PETITION FOR A WRIT OF CERTIORARI TO

THE UNITED STATES COURT OF APPEALS

FOR THE SIXTH CIRCUIT

______________________________________________________

APPENDIX TO

PETITION FOR A WRIT OF CERTIORARI

Joshua Michael Reho

Counsel of Record

Scott T. Wendelsdorf

Office of the Federal Defender

200 Theatre Building

629 Fourth Avenue

Louisville, Kentucky 40202

(502) 584-0525

Josh_Reho@fd.org

Counsel for Petitioner

Index

Item

Page

Appendix A

Sixth Circuit Court of Appeals Opinion

Appendix B

Western District of Kentucky Judgment

17a

Appendix C

Sixth Circuit Order Denying Panel Rehearing

25a

Appendix D

Transcript of Sentencing Hearing

26a

Appendix E

Sentencing Guideline and Statutory Provisions Involved

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RECOMMENDED FOR PUBLICATION

Pursuant to Sixth Circuit I.O.P. 32.1(b)

File Name: 26a0144p.06

UNITED STATES COURT OF APPEALS

FOR THE SIXTH CIRCUIT

UNITED STATES OF AMERICA,

Plaintiff-Appellee/Cross-Appellant,

MIRSAD RAMIC,

Defendant-Appellant/Cross-Appellee.

┐

│

┘

Nos. 25-5392/5471

Appeal from the United States District Court

for the Western District of Kentucky at Bowling Green.

No. 1:21-cr-00013-1—Gregory N. Stivers, District Judge.

Argued: April 30, 2026

Decided and Filed: May 13, 2026

Before: GIBBONS, THAPAR, and LARSEN, Circuit Judges.

_________________

COUNSEL

ARGUED: Joshua M. Reho, WESTERN KENTUCKY FEDERAL COMMUNITY

DEFENDER, INC., Louisville, Kentucky for Mirsad Ramic. Amanda E. Gregory, UNITED

STATES ATTORNEY’S OFFICE, Louisville, Kentucky, for the United States. ON BRIEF:

Frank W. Heft, Jr., Scott T. Wendelsdorf, OFFICE OF THE FEDERAL DEFENDER,

Louisville, Kentucky, for Mirsad Ramic.

Amanda E. Gregory, UNITED STATES

ATTORNEY’S OFFICE, Louisville, Kentucky, for the United States.

_________________

OPINION

_________________

THAPAR, Circuit Judge. Over a decade ago, a new wave of terrorism spread across the

Middle East. A group calling itself the Islamic State of Iraq and Syria (ISIS) sought to establish

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a new regime strictly governed by Islamic law. To do so, ISIS employed brutal tactics—planting

bombs, publicly decapitating its enemies, burning people alive, and enslaving women and

children. It also launched vicious attacks to conquer territory in Iraq and Syria. And it recruited

fighters from around the world to perform these acts of terrorism.

Mirsad Ramic was one such fighter. He traveled from the United States to Syria, where

he participated in an attack that claimed over 100,000 lives. The United States eventually

prosecuted him for providing material support to a terrorist group and receiving military-type

training from that group. For those crimes, Ramic faced an advisory sentence of 360 to 600

months’ imprisonment under the Sentencing Guidelines. But the district court sentenced Ramic

to only 101 months in prison. Because the district court’s substantial variance is substantively

unreasonable, we vacate his sentence and remand for resentencing.

Mirsad Ramic grew up in Bosnia during a civil war. That conflict involved genocide and

war crimes targeted at minority groups, including Bosnian Muslims like Ramic and his family.

In fact, Ramic’s father was killed during this conflict. So once the war concluded, the United

States offered Ramic and his family a fresh start by granting them refugee status. Ramic’s

family ultimately settled in Bowling Green, Kentucky, a city with a vibrant population of other

Bosnian refugees. Eventually, Ramic became a naturalized U.S. citizen, but he was unhappy

with his American life.

Rather than embracing the privilege of American citizenship, Ramic embraced the

extremist views of terrorist groups trying to destroy the United States and its allies. During his

naturalization ceremony, Ramic refused to recite the oath of allegiance to the United States.

Instead, he proclaimed an Islamic oath and cursed all nonbelievers.

Less than a year later, Ramic attempted to travel to the Middle East and join a terrorist

group. First, he tried traveling to Yemen, claiming that he wanted to enroll in a religious school

there. But he didn’t have a student visa, so Yemeni authorities denied him entry.

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This trip raised the suspicions of American law enforcement, leading FBI agents to

question Ramic several times about the reason for his travel. Ramic insisted that he simply

wanted to engage in religious study. But the agents didn’t believe him. Instead, they thought he

was being radicalized and wanted to join terrorist groups engaged in jihad—which, in the

terrorism context, means a religious holy war against those who don’t believe in Islam. The

federal agents were right to be suspicious: Ramic later admitted that he had lied about why he

traveled to Yemen. But they took no action at the time.

Neither the FBI interviews nor his failed attempt to join a jihadist group deterred Ramic.

He then joined an online chat service to connect with other supporters of terrorism. In those

chats, Ramic discussed his continued desire to travel to Muslim countries. And he urged others

to do the same by obtaining student visas to study Arabic. Ramic followed his own advice and

twice applied to study at a university in Saudi Arabia. He tried to secure a student visa to travel

there, but that plan never came to fruition.

Around this time, ISIS began gaining power in the Middle East. It aimed to establish a

global empire with strict enforcement of Islamic law. It started by conquering large swaths of

territory in Syria and Iraq. In doing so, ISIS used ruthless tactics, such as public executions,

enslavement, and car bombings that targeted civilians. For example, ISIS publicly murdered

journalists to demonstrate the consequences of dissent. And ISIS’s reign of terror wasn’t limited

to Iraq and Syria. ISIS launched attacks around the world, including in France and Belgium. In

response, the United States designated ISIS as a foreign terrorist organization in 2014 and led an

international effort to combat this growing threat. ISIS also declared the United States an enemy

and urged its followers to attack the United States and its interests.

One such follower was Abdullah el-Faisal. Faisal was a Jamaican Muslim cleric who had

previously been convicted in the United Kingdom of advocating for the murder of Jews, Hindus,

Christians, and Americans. When ISIS started gaining traction, Faisal began recruiting for the

group and urged his supporters to launch violent jihadist attacks. He instructed his followers on

how to covertly travel to Syria or Iraq to join ISIS. Ramic consumed this radical propaganda and

soon ascended to Faisal’s inner circle, becoming one of the few people trusted to directly raise

money on Faisal’s behalf.

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Ramic then put Faisal’s instructions into action and traveled to Syria to join ISIS. Upon

arriving in Syria, Ramic completed an ISIS intake form, indicating that he wished to become a

fighter. To prepare for battle, Ramic went through military-style training where he learned

warfare tactics and how to use combat weapons. His classmates recalled that he expressed a

particular interest in automatic weapons and sniper rifles.

After completing his training, Ramic fought in the siege of Kobane, a city in northern

Syria. He was on the front lines of the initial assault on the city. During this battle, ISIS

primarily fought against a local militia group. But the United States also supported that local

militia, launching air strikes against ISIS forces. Though the attack was ultimately unsuccessful,

ISIS wreaked enormous havoc on the city and its populace, displacing hundreds of thousands of

civilians and committing numerous atrocities.

Roughly 100,000 people died during the

campaign.

Following the siege of Kobane, Ramic continued to support ISIS’s mission. He posted

on social media, praising ISIS’s public beheading of Coptic Christians in Libya, boasting about

how many bodies he could fit in the back of a car, and bragging that he had “slave girls” cleaning

his house. R. 326, Pg. ID 5462.

Ramic also told a friend that he wanted to become a martyr for ISIS. He would’ve

followed through with that goal, but ISIS made martyrs wait for approximately six months

before launching their suicide missions. That wait was simply too long for Ramic, who became

frustrated and abandoned that goal.

Eventually, Ramic became disillusioned with ISIS. He was disappointed that it didn’t

“apply[] Islamic principles” strictly enough and that the people he met in Syria “did not practice

the Muslim faith at all.” R. 291-1, Pg. ID 4420, 4423. So he decided to abandon ISIS and travel

to Turkey instead.

Once Ramic entered Turkey, Turkish authorities arrested him for engaging in terrorism.

After holding him in custody for five years, Turkish authorities turned Ramic over to the United

States. A grand jury in the Western District of Kentucky then charged him with conspiring to

provide and providing material support to a foreign terrorist organization and receiving military-

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type training from such an organization. Ramic went to trial, and a jury convicted him of all

charges. The district court calculated Ramic’s advisory Guidelines range as 360 to 600 months’

imprisonment. But the district court sentenced Ramic to just 101 months’ imprisonment—72

percent below the bottom of the Guidelines range.

The district court attempted to justify its sentence in two primary ways. First, it stated

that Ramic didn’t engage “in any acts of terrorism as . . . in a more common sense”

understanding of the term. R. 311, Pg. ID 4785. It explained, for example, that Ramic hadn’t

engaged in any “random acts of violence directed at innocent populations,” detonated any

“bombs,” or inflicted any “horrible incidents of gun violence against crowds.” Id. Instead, the

district court concluded that Ramic was merely a “fighter” and a “soldier” who joined “a

standard army” that wanted to “require strict adherence to [Islamic] law.” Id. Second, the

district court noted that the median sentence for terrorism defendants with the same offense level

and criminal-history category was only 168 months’ imprisonment. Using that median sentence

as a starting point, the district court subtracted the 67 months that Ramic spent in Turkish

custody and arrived at a final sentence of 101 months.

Ramic timely appealed, challenging the district court’s calculation of his Guidelines

range. And the government timely cross-appealed, challenging the length of Ramic’s sentence.

II.

Ramic argues that his sentence is procedurally unreasonable because the district court

incorrectly calculated his Guidelines range. See Gall v. United States, 552 U.S. 38, 51 (2007).

Specifically, he contends that the district court improperly applied a sentencing enhancement for

terrorism offenses. See U.S.S.G. § 3A1.4. We review the district court’s legal interpretation of

the terrorism enhancement de novo and its factual findings for clear error. United States v.

Wright, 747 F.3d 399, 407 (6th Cir. 2014).

The terrorism enhancement applies to any “felony that involved, or was intended to

promote, a federal crime of terrorism.” U.S.S.G. § 3A1.4. And the Guidelines define a “federal

crime of terrorism” by reference to 18 U.S.C. § 2332b(g)(5). Id. § 3A1.4 cmt. n.1. That statute

provides that a federal crime of terrorism “is calculated to influence or affect the conduct of

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government by intimidation or coercion, or to retaliate against government conduct.” 18 U.S.C.

§ 2332b(g)(5).

Ramic argues that the term “government” includes only governments that the President

has recognized. He then contends that condition isn’t satisfied here because ISIS fought against

only the Kurdistan Workers’ Party, which is a nonstate actor, and the Assad regime, which

wasn’t the recognized government of Syria. But that argument fails.

Neither the terrorism statute nor the Sentencing Guidelines defines the term

“government.” So we rely on its ordinary meaning. See Perrin v. United States, 444 U.S. 37, 42

(1979); see also United States v. Ansberry, 976 F.3d 1108, 1128 & n.11 (10th Cir. 2020)

(defining “government” for purposes of the terrorism enhancement using ordinary dictionary

definitions).

The ordinary meaning of “government” refers to “the body of persons that

constitutes the governing authority of a political unit or organization.” Government, Webster’s

Third New International Dictionary (1961); see also Government, Oxford English Dictionary (2d

ed. 1989) (“The governing power in a state; the body of persons charged with the duty of

governing.”); Government, Black’s Law Dictionary (6th ed. 1990) (“[T]he framework of political

institutions, departments, and offices, by means of which the executive, judicial, legislative, and

administrative business of the state is carried on.”). Notice what’s missing: Those definitions

aren’t limited to governments that the United States has formally recognized.

If Congress wanted to use a specialized definition of the term “government,” it could

have done so. See Gallardo ex rel. Vassallo v. Marstiller, 596 U.S. 420, 429 (2022). In fact,

Congress has used specialized definitions for other terms in the terrorism statutes. See, e.g., 18

U.S.C. § 2332f(e)(12) (defining “state” as having “the same meaning as that term has under

international law”). So Congress’s choice not to include a specific definition of “government” in

§ 2332b indicates that the term carries its ordinary meaning.

Ramic doesn’t contest that the Assad regime falls within the ordinary meaning of

“government.”

Instead, he makes a constitutional argument:

Only the President has the

authority to recognize foreign governments, and the President didn’t recognize the Assad regime

as the legitimate government of Syria when Ramic joined ISIS. To be sure, the President has the

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“exclusive power” to recognize foreign governments. Zivotofsky ex rel. Zivotofsky v. Kerry, 576

U.S. 1, 32 (2015). But the Supreme Court has made clear that “[t]he Executive’s exclusive

power extends no further than his formal recognition determination.” Id. at 30 (emphasis

added). That means Congress can still legislate pursuant to its own powers, which include the

power “[t]o define and punish . . . Offences against the Law of Nations.” U.S. Const. art. I, § 8,

cl. 10; see Zivotofsky, 576 U.S. at 16. And that’s precisely what Congress did when it defined a

federal crime of terrorism as conduct directed at a government, regardless of whether the United

States has recognized that government. See Antiterrorism and Effective Death Penalty Act of

1996, Pub. L. No. 104-132, § 301, 110 Stat. 1214, 1247. In short, the President’s “narrow” slice

of exclusive power over recognition leaves Congress with plenty of room to craft a definition of

terrorism that relies on the ordinary meaning of government.

In response, Ramic says that even if Congress didn’t explicitly infringe on the President’s

recognition power, applying the terrorism enhancement here would implicitly recognize the

Assad regime as the government of Syria, thus contradicting the President. But recognition

generally requires express, unambiguous statements or a narrow subset of formal diplomatic

actions. See Zivotofsky, 576 U.S. at 11. Those actions include issuing an official declaration,

entering a treaty with the other government, and sending or receiving ambassadors. See id. at

11–12; see also Restatement (Third) of Foreign Relations Law of the United States § 204 rptr.

n.2 (Am. L. Inst. 1987). In other words, determining that an entity falls within the ordinary

meaning of government doesn’t count as formal recognition. As a result, a court’s decision that

an entity is a government under § 2332b doesn’t change whether the United States formally

recognizes that government. Nor does it compel the Executive Branch to take any diplomatic

action. So it doesn’t step on the President’s toes. That means the district court didn’t err by

concluding that Ramic’s conduct directed at the Assad regime justified applying the terrorism

enhancement.

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But even if the Assad regime didn’t count as a government under § 2332b, the terrorism

enhancement would still apply here. That’s because Ramic’s conduct was also calculated to

influence or affect the United States.1 Before Ramic joined ISIS, the group had declared war on

the United States and issued religious decrees encouraging its supporters to attack American

interests. Courts have therefore recognized that “ISIS’s terrorist acts are intended to intimidate

or coerce the United States,” so a defendant’s provision of material support to ISIS is evidence

that he sought to influence the United States. United States v. Khan, 938 F.3d 713, 719 (5th Cir.

2019).

In fact, Ramic openly embraced ISIS’s mission to target the United States. For example,

he posted on social media that he hoped President Obama’s teenage daughters would one day be

sold as ISIS slaves. Cf. United States v. Van Haften, 881 F.3d 543, 544–45 (7th Cir. 2018)

(applying the terrorism enhancement to an ISIS supporter who posted on social media that he

wanted to see President Bush’s and President Obama’s children and grandchildren “sold as

slaves at [ISIS] markets”). Ramic also posted a picture of a brochure given to the families of

American soldiers who died in combat next to a picture of assault rifles. Alongside those

pictures, Ramic wrote that he wanted “[t]o make more of them fall”—that is, to kill more

American soldiers. R. 326, Pg. ID 5451. So Ramic’s own words make clear that his support of

ISIS was calculated to affect the United States.

What’s more, the evidence at trial indicated that Ramic fought against American forces in

the siege of Kobane. During the early stages of the battle, Ramic posted on social media that

“planes [were] circling and drones hovering.” Id. at 5460. Later that same day, he posted about

the difference in diameter between the holes left by American bombs and those left by the Assad

regime’s bombs. An expert witness also testified that the United States launched air strikes

1Ramic argues that the government either waived or forfeited this argument because it didn’t object to a

passage in the presentence investigation report (PSR) stating that ISIS fought against the Assad regime and the

Kurdistan Workers’ Party. But this argument fails. First, that paragraph was accurate, and the government had no

obligation to object. Importantly, the paragraph didn’t say that ISIS was fighting against only the Assad regime and

the Kurdistan Workers’ Party. Indeed, other sections of the PSR indicated that ISIS was fighting against the United

States, too. Second, the government argued in its sentencing memorandum that the district court could apply the

enhancement based on Ramic’s conduct targeted at the United States. And even if that weren’t enough to preserve

the argument, the government was the prevailing party on this issue, so it can rely on any ground in the record to

support the judgment below. Dandridge v. Williams, 397 U.S. 471, 475 n.6 (1970).

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against ISIS forces at Kobane.

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This evidence demonstrates that Ramic knowingly battled

American forces during the siege of Kobane.

In sum, the government established by a preponderance of the evidence that Ramic’s

conduct was calculated to influence or affect not only the Assad regime but also the United

States. As a result, the district court didn’t err in applying the terrorism enhancement, and

Ramic’s sentence wasn’t procedurally unreasonable.

III.

The government also cross-appealed, arguing that Ramic’s sentence is substantively

unreasonable because it’s too low. A sentence is substantively unreasonable if “the court placed

too much weight on some of the § 3553(a) factors and too little on others in sentencing the

individual.” United States v. Rayyan, 885 F.3d 436, 442 (6th Cir. 2018). Here, the district court

didn’t adequately weigh the seriousness of Ramic’s crime, potential sentencing disparities, and

the need to protect the public.

When a district court imposes a below-Guidelines sentence, it “must consider the extent

of the deviation and ensure that the justification is sufficiently compelling to support the degree

of the variance.” Gall, 552 U.S. at 50. So a larger variance requires a more compelling

rationale. Id. Because the district court’s rationale here didn’t justify such a drastic downward

variance, we conclude that Ramic’s sentence is substantively unreasonable.

For starters, the district court minimized the seriousness of Ramic’s conduct. This led the

district court to impose a sentence that didn’t reflect the “seriousness of the harm” caused by

Ramic’s terrorism offenses.

United States v. Boucher, 937 F.3d 702, 710 (6th Cir. 2019)

(quotation omitted). And that makes Ramic’s sentence substantively unreasonable.

Throughout sentencing, the district court downplayed ISIS’s mission and Ramic’s

actions. It described Ramic’s conduct as “participation in an organized army intent on capturing

a piece of territory for the creation of their own state.” R. 311, Pg. ID 4786. And it repeatedly

characterized Ramic as a “soldier” and “fighter” who merely “went to join an army.” Id. at

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4785–86. But Ramic was no ordinary soldier. That’s because ISIS isn’t an army governed by

the laws of war or a code of ethics like our armed forces. It’s a terrorist group that has engaged

in countless atrocities. See United States v. Khan, 997 F.3d 242, 248 (5th Cir. 2021) (finding a

sentence substantively unreasonable when the district court compared a prospective ISIS fighter

to someone “signing up for the Marines”).

And if there were any doubt about ISIS’s brutality, the government proved it at trial.

First, the government established that ISIS carried out a large suicide attack at a mosque in

Kuwait. Then, ISIS targeted Belgium, where a member began shooting inside a museum,

murdering four people. Around the same time, ISIS executed 700 cadets at a military school in

Iraq, killing one young soldier after another. And the following year, ISIS publicly beheaded 21

Coptic Christians simply because those innocent civilians dared to practice their faith.

What’s more, the government showed that Ramic embraced ISIS’s radical beliefs and

atrocities. On social media, he hoped for the day when President Obama’s daughters would “be

sold as [slaves] in one of the local markets.”

R. 299, Pg. ID 4558.

He threatened the

“rafidah/shia” Muslims that they must convert to Sunni Islam “or Die.” Id. at 4561. He posted a

photo of a United States “fallen veterans” brochure alongside an ISIS flag and rifles and asked

others if they were “ready for a joint mission” to “make more [U.S. soldiers] fall.” R. 326, Pg.

ID 5450–51. And he celebrated the beheadings of the Coptic Christians: “If [J]esus was alive

today he would be with Islamic State, and behead #Copts for taking him as god besides Allah.”

R. 299, Pg. ID 4560. The district court, however, failed to address these posts in determining the

seriousness of Ramic’s offense. See United States v. Medlin, 65 F.4th 326, 331 (6th Cir. 2023).

The district court’s characterization of ISIS (and Ramic’s support for its cause) matters

because Ramic was convicted of providing material support to a terrorist group. So the court

needed to consider the nature of the terrorist group Ramic supported to properly evaluate the

seriousness of his offense.

See Khan, 997 F.3d at 248 (finding a sentence substantively

unreasonable when the district court “failed to acknowledge that [the defendant] had facilitated

and fully supported the purposes and atrocities of ISIS”). In other words, the more violent and

brutal the terrorist organization, the more serious it is to provide material support to that group.

In this case, Ramic intended to help ISIS gain power and territory so that it could wage a global

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jihad. Plus, Ramic’s participation meant that ISIS needed one fewer fighter on the battlefield in

Syria and could instead afford to send its members to commit terrorist attacks around the world.

The district court’s failure to grapple with ISIS’s brutalities or recognize how Ramic’s efforts

facilitated those atrocities caused it to understate the seriousness of his crimes.

The district court also stated that Ramic’s actions didn’t involve “any acts of senseless

violence against innocent people.” R. 311, Pg. ID 4785. But that ignores the district court’s own

factual findings. The district court adopted the PSR without change. The PSR explicitly noted

that the siege of Kobane—which Ramic participated in—led to the displacement of hundreds of

thousands of civilians and the deaths of about 100,000 people. The PSR further explained that

ISIS engaged in atrocities against civilians in the area. Granted, there’s no specific evidence

about what Ramic did during the siege. But we know that his participation in the siege of

Kobane supported ISIS’s commission of brutalities. And we know that he abused civilians by

forcing “slave girls” to clean his house. R. 323, Pg. ID 5258. So the record—including the

district court’s own factual findings—undermines the court’s assertion that Ramic’s conduct

didn’t involve “senseless violence” against civilians.

Finally, the district court downplayed Ramic’s crimes by claiming that he didn’t engage

“in any acts of terrorism . . . in a more common sense” understanding of that term. R. 311, Pg.

ID 4785. Specifically, the district court emphasized that “[t]here were no bombs” or “horrible

incidents of gun violence against crowds.” Id. First, we don’t know whether that’s true—ISIS

regularly targeted civilians with bombs and guns. Second, even though there’s no specific

evidence that Ramic engaged in such conduct, the district court’s rationale still doesn’t justify

such a substantial downward variance. See Gall, 552 U.S. at 50. A district court must ensure

that a sentence “meshes with Congress’s own view of the crime[’s] seriousness.” United States

v. Musgrave, 761 F.3d 602, 608 (6th Cir. 2014) (cleaned up). And Congress adopted a broader

definition of material support that extends beyond just launching bombs or shooting into a

crowd. See 18 U.S.C. § 2339A(b)(1) (defining “material support” as “any property, tangible or

intangible, or service, including currency or monetary instruments or financial securities,

financial services, lodging, training, expert advice or assistance, safehouses, false documentation

or identification, communications equipment, facilities, weapons, lethal substances, explosives,

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personnel . . . , and transportation”).

By fixating on its own unduly narrow conception of

terrorism, the district court ignored its obligation to craft a sentence that reflects Congress’s

broader view of that crime.

Combined, these mistakes led the district court to impose an unduly lenient sentence that

doesn’t reflect the seriousness of Ramic’s offenses.

In addition to understating the seriousness of Ramic’s conduct, the district court placed

too much weight on national sentencing data. The district court started with the median sentence

for terrorism defendants with the same criminal-history category and offense level as Ramic,

which was 168 months. It then subtracted 67 months for the time Ramic spent in Turkish

custody and arrived at a final sentence of 101 months’ imprisonment.

It’s true that a district court must consider whether a sentence will create unwarranted

disparities among similarly situated defendants. See 18 U.S.C. § 3553(a)(6). But a district court

accounts for those disparities by correctly calculating a defendant’s Guidelines range. United

States v. Hymes, 19 F.4th 928, 935 (6th Cir. 2021). And while a district court may consider

national statistics to evaluate potential sentencing disparities, district courts may not “elevate the

Commission’s statistical data over the text of the Guidelines themselves.” Id. at 936. That’s

because it is the role of the Sentencing Commission—not district courts—to update the

Guidelines in response to new empirical data. Id. Plus, sentencing statistics have important

limitations that can prevent district courts from making meaningful comparisons between cases.

For example, the data may be “so general that it often is difficult to know whether offenders

grouped into the same primary offense category have indeed been found guilty of similar

conduct.” United States v. Stock, 685 F.3d 621, 629 n.6 (6th Cir. 2012) (cleaned up). In short,

even though national sentencing statistics can sometimes provide helpful information, they can’t

displace the Sentencing Guidelines as the principal measure of whether a sentence would

produce unwarranted disparities.

Here, the district court allowed national statistics to control its sentencing decision and

failed to justify that decision. The district court started with the median sentence for similarly

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situated offenders, even though it admitted it didn’t “have a whole lot of texture to what these

other defendants did.” R. 311, Pg. ID 4786. Without any comparison to other defendants, it

asserted that it “tend[ed] to view this more along the median of 168 months.” Id. And in doing

so, the district court ignored significant gaps in the sentencing data. First, the relevant sample

size included only nine other defendants. So it’s possible the data was skewed by one or two

outlier cases.

Second, the bare sentencing data didn’t explain the severity of the other

defendants’ crimes, specify whether they accepted responsibility, or indicate whether they had

been rehabilitated.

Despite the lack of these key details, the district court still somehow

determined that Ramic’s conduct was “along the median of 168 months.” Id. But without more

information, the district court had little basis to conclude that Ramic was similarly situated to

those other defendants. Did they travel to Syria and actually fight in a war? Did they boast

about their activities and their hatred for America? We don’t know.

Indeed, compared to other defendants who engaged in conduct like Ramic’s, his sentence

is shockingly low. Courts have regularly imposed far longer sentences for defendants convicted

of providing material support to ISIS.2 And many of those defendants’ conduct was much less

egregious than Ramic’s. Some didn’t make it out of the country or reach the battlefield. 3 Others

provided small sums of money to support ISIS’s goals but received more jail time than Ramic. 4

Contrast those defendants with Ramic, who actively participated in an attack that claimed the

2See, e.g., United States v. Carpenter, 157 F.4th 841, 846, 855 (6th Cir. 2025) (240 months for defendant

who merely provided translation services for ISIS); United States v. Rahim, 860 F. App’x 47, 49–50 (5th Cir. 2021)

(per curiam) (360 months for defendant who ran ISIS social-media channel and encouraged individuals to join

ISIS); United States v. Langhorne, No. 22-12412, 2024 WL 2018545, at *1 (11th Cir. May 7, 2024) (per curiam)

(240 months for defendant who produced a video for ISIS on how to make a bomb); United States v. Blanco, 102

F.4th 1153, 1157–58 (11th Cir. 2024) (192 months for defendant who ran two unofficial ISIS social-media

channels); United States v. Khweis, No. 22-4406, 2023 WL 4993685, at *1 (4th Cir. Aug. 8, 2023) (168 months for

defendant who provided administrative support to ISIS).

3See, e.g., United States v. Alebbini, 979 F.3d 537, 539, 543 (6th Cir. 2020) (180 months for defendant who

attempted to travel to Syria to join ISIS but was arrested at the airport); United States v. Masood, 133 F.4th 799,

803–04 (8th Cir. 2025) (216 months for defendant who attempted to travel to ISIS-controlled territory but was

arrested at the airport); see also R. 299, Pg. ID 4575 (240 months for defendant who traveled to join ISIS but was

arrested before reaching ISIS-controlled territory).

4See, e.g., United States v. Young, 818 F. App’x 185, 188–89 (4th Cir. 2020) (per curiam) (180 months for

defendant who advised someone on how to join ISIS and sent him $245); United States v. Khusanov, No. 25-14,

2026 WL 21000, at *1 (2d Cir. Jan. 5, 2026) (132 months for defendant who provided between $200 and $400 to

fund another individual’s travel to join ISIS).

13a

Case: 25-5392

Nos. 25-5392/5471

Document: 66-2

Filed: 05/13/2026

United States v. Ramic

Page: 14

(15 of 18)

Page 14

lives of over 100,000 people. Far from avoiding sentencing disparities, the district court created

a disparity by imposing a sentence on Ramic that was lower than what other ISIS supporters

received.

The district court also failed to properly weigh the need to protect the public from

Ramic’s potential future crimes. See 18 U.S.C. § 3553(a)(2)(C). Terrorism poses “a particularly

grave threat because of the dangerousness of the crime and the difficulty of deterring and

rehabilitating the criminal,” so “terrorists and their supporters should be incapacitated for a

longer period of time.” United States v. Meskini, 319 F.3d 88, 92 (2d Cir. 2003). Indeed,

empirical research on Americans who traveled to join jihadist groups in Syria and Iraq supports

these observations. Even after returning to the United States, those individuals still pose a threat

because they can support local jihadist networks, share their knowledge on how to conduct

terrorist attacks, and recruit new members. Alexander Meleagrou-Hitchens, Seamus Hughes &

Bennett Clifford, The Travelers: American Jihadists in Syria and Iraq 2 (Feb. 2018). But the

district court didn’t even mention the possibility that Ramic could pose such a risk after his

release.

In fact, there are strong reasons to be concerned that Ramic will return to terrorist

activities after serving his prison sentence. First, under the district court’s sentence, Ramic

would be released at age 39, so he would still be capable of launching future attacks. See United

States v. Ressam, 679 F.3d 1069, 1090 (9th Cir. 2012) (noting that a defendant released at age 51

would be “sufficiently active and capable . . . to do considerable damage” especially in light of

his “strongly held beliefs” and “willingness to attack American interests”). Second, Ramic

received military-type training from ISIS. That means he’s “far more sophisticated than an

individual convicted of an ordinary street crime” and thus “poses a heightened risk of future

dangerousness.” United States v. Jayyousi, 657 F.3d 1085, 1117 (11th Cir. 2011). The district

court should have accounted for both of these risks.

14a

Case: 25-5392

Document: 66-2

Nos. 25-5392/5471

Filed: 05/13/2026

United States v. Ramic

Page: 15

(16 of 18)

Page 15

Perhaps most importantly, Ramic hasn’t disavowed terrorism. He left ISIS not because

he disagreed with the group’s mission or its brutal tactics, but because he believed ISIS was

corrupt. And his failure to renounce terrorism means it’s possible that he would join another

terrorist organization in the future.

Plus, Ramic hasn’t demonstrated remorse or accepted responsibility for his crimes. At

sentencing, he delivered a lengthy monologue, stretching over 11 pages of the sentencing

transcript, in which he lambasted the case against him. Ramic insisted that he was “an innocent

man” and that he “completely reject[ed]” the charges against him. R. 311, Pg. ID 4772. He

claimed it was a “sham prosecution from the start” that was “brought by biased,

prejudiced, . . . rogue[,] and corrupt prosecutors . . . with a compromised grand jury.”

Id.

Ramic’s belief that he did absolutely nothing wrong is yet another indication that he may return

to terrorism upon his release. And he may now have an additional motive to attack the United

States after serving a prison sentence for what he believes was a “sham prosecution.” Id. Once

again, the district court didn’t address Ramic’s lack of remorse and potential future threat to the

public.

These concerns about Ramic returning to terrorism upon his release aren’t merely

hypothetical. Courts’ refusals to incapacitate terrorists for a long period of time have had deadly

consequences. See, e.g., Katrin Bennhold, Melissa Eddy & Christopher F. Schuetze, Vienna

Reels From a Rare Terrorist Attack, N.Y. Times (Oct. 9, 2021) (describing a terrorist who was

sentenced to just 22 months in prison for traveling to join ISIS, was released after one year, and

then launched an attack in Vienna that killed four people and wounded another 23); Sadie

Gurman, Old Dominion Shooting Suspect Had ISIS Conviction, Was Subdued by Students, Wall

St. J. (Mar. 12, 2026, at 19:00 ET) (describing a terrorist who provided material support to ISIS,

received a sentence far below the Guidelines range, was released, and then opened fire in a

university classroom, killing the instructor and wounding two others). The district court here

repeated that mistake and didn’t reckon with the very real possibility that Ramic could

participate in future attacks after his release. When sentencing terrorists, protecting the public is

of primary importance. The district court’s failure to properly weigh this factor when dealing

with Ramic makes his sentence substantively unreasonable.

15a

Case: 25-5392

Nos. 25-5392/5471

Document: 66-2

Filed: 05/13/2026

United States v. Ramic

Page: 16

(17 of 18)

Page 16

For the foregoing reasons, we vacate Ramic’s sentence and remand for resentencing

consistent with this opinion.

16a

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Document 308

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Filed 04/15/25

Page 1 of 8 PageID #:

USDC KYWD 245B (Rev. 02/16) Judgment in a Criminal Case Sheet 1

United States District Court

Western District of Kentucky

BOWLING GREEN DIVISION

UNITED STATES OF AMERICA

Mirsad Ramic

JUDGMENT IN A CRIMINAL CASE

(For Offenses Committed On or After November 1, 1987)

Case Number: 1:21-CR-13-GNS-1

US Marshal No: 79222-509

Counsel for Defendant: Scott T. Wendelsdorf, Federal Public Defender, Appointed

Counsel for the United States: Joshua Judd and Christopher C. Tieke, Asst. U.S. Attys.

and Kevin C. Nunnally, USDOJ Trial Attorney

Court Reporter: Digitally Recorded Proceedings (ECRO: DeAnna Whitney)

THE DEFENDANT:

☐ Pursuant to plea agreement

☐ Pleaded guilty to count(s)

☐ Pleaded nolo contendere to count(s)

which was accepted by the court.

☒ Was found guilty on counts 1, 2, and 3 of the Indictment on 6/11/2024 after a plea of not guilty.

ACCORDINGLY, the Court has adjudicated that the defendant is guilty of the following offense(s):

Title / Section and Nature of Offense

Date Offense

Concluded

Count

FOR CONVICTION OFFENSE(S) DETAIL - SEE COUNTS OF CONVICTION ON PAGE 2

The defendant is sentenced as provided in pages 2 through 8 of this Judgment. The sentence is imposed pursuant to the

Sentencing Reform Act of 1984.

☐ The defendant has been found not guilty on count(s)

☐ Count(s)

(Is) (are) dismissed on the motion of the United States.

IT IS ORDERED that the defendant shall notify the United States Attorney for this district within 30 days of any change of name,

residence, or mailing address until all fines, restitution, costs and special assessments imposed by this judgment are fully paid. If ordered

to pay restitution, the defendant shall notify the Court and the United States Attorney of any material change in the defendant's economic

circumstances.

4/14/2025

Date of Imposition of Judgment

April 15, 2025

17a

Appendix B

Case 1:21-cr-00013-GNS-HBB

Document 308

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Page 2 of 8 PageID #:

USDC KYWD 245B (Rev. 02/16) Judgment in a Criminal Case Sheet 1A

Judgment-Page 2 of 8

DEFENDANT: Ramic, Mirsad

CASE NUMBER: 1:21-CR-13-GNS-1

COUNTS OF CONVICTION

Title / Section and Nature of Offense

18:2339B(a)(1), (d)(1)(C), (E), and (F), 3238, and 2-MATERIAL SUPPORT

18:2339B(a)(1), (d)(1)(C), (E) and (F), and 3238-CONSPIRACY TO PROVIDE MATERIAL

SUPPORT

18:2339D(a), (b)(1), (b)(3), (b)(5), and (b)(6), and 3238-RECEIPT OF MILITARY-TYPE

TRAINING FROM A FOREIGN TERRORIST ORGANIZATION

18a

Date Offense

Concluded

Count

9/2015

Case 1:21-cr-00013-GNS-HBB

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Page 3 of 8 PageID #:

USDC KYWD 245B (Rev. 02/16) Judgment in a Criminal Case Sheet 2 - Imprisonment

Judgment-Page 3 of 8

DEFENDANT: Ramic, Mirsad

CASE NUMBER: 1:21-CR-13-GNS-1

IMPRISONMENT

The defendant is hereby committed to the custody of the Federal Bureau of Prisons to be imprisoned for a total term of 101

months as to each of Counts 1 and 2 in the Indictment, which shall be served concurrently, for a TOTAL TERM OF 101

MONTHS.

☐ The Court makes the following recommendations to the Bureau of Prisons:

☒ The defendant is remanded to the custody of the United States Marshal.

☐ The defendant shall surrender to the United States Marshal for this district:

☐ at

A.M. / P.M. on

☐ as notified by the United States Marshal.

☐ The defendant shall surrender for service of sentence at the institution designated by the Bureau of Prisons:

☐ Before 2:00 p.m. on

☐ as notified by the United States Marshal.

☐ as notified by the Probation or Pretrial Services Office.

☐ The defendant shall continue under the terms and conditions of his/her present bond pending surrender to the institution.

RETURN

I have executed this judgment as follows:

Defendant delivered on

, with a certified copy of this judgment.

UNITED STATES MARSHAL

19a

Deputy U.S. Marshal

Case 1:21-cr-00013-GNS-HBB

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USDC KYWD 245B (Rev. 02/16) Judgment in a Criminal Case Sheet 3 - Supervised Release

Judgment-Page 4 of 8

DEFENDANT: Ramic, Mirsad

CASE NUMBER: 1:21-CR-13-GNS-1

SUPERVISED RELEASE

Upon release from imprisonment, the defendant shall be on supervised release for a term of: LIFE as to each of Counts 1 and 2 of the

Indictment, which shall be served currently, for a TOTAL TERM OF LIFE.

MANDATORY CONDITIONS

You must not commit another federal, state or local crime.

You must not unlawfully possess a controlled substance.

You must refrain from any unlawful use of a controlled substance. You must submit to one drug test within 15 days of release from

imprisonment and at least two periodic drug tests thereafter, as determined by the court.

☐ The above drug testing condition is suspended, based on the court's determination that you pose a low risk of future

substance abuse.

☐ You must make restitution in accordance with 18 U.S.C. §§ 3663 and 3663A or any other statute authorizing a sentence of

restitution. (check if applicable)

☒ You must cooperate in the collection of DNA as directed by the probation officer.

☐ You must comply with the requirements of the Sex Offender Registration and Notification Act (34 U.S.C. § 20901, et seq.) as

directed by the probation officer, the Bureau of Prisons, or any state sex offender registration agency in which you reside, work, are

a student, or were convicted of a qualifying offense.

☐ You must participate in an approved program for domestic violence.

You must comply with the standard conditions that have been adopted by this court as well as with any other conditions on the attached

page.

20a

Case 1:21-cr-00013-GNS-HBB

Document 308

4722

Filed 04/15/25

Page 5 of 8 PageID #:

USDC KYWD 245B (Rev. 02/16) Judgment in a Criminal Case Sheet 3A - Supervised Release

Judgment-Page 5 of 8

DEFENDANT: Ramic, Mirsad

CASE NUMBER: 1:21-CR-13-GNS-1

STANDARD CONDITIONS OF SUPERVISION

As part of your supervised release, you must comply with the following standard conditions of supervision. These conditions are imposed

because they establish the basic expectations for your behavior while on supervision and identify the minimum tools needed by probation

officers to keep informed, report to the court about, and bring about improvements in your conduct and condition.

You must report to the probation office in the federal judicial district where you are authorized to reside within 72 hours of your

release from imprisonment, unless the probation officer instructs you to report to a different probation office or within a different

time frame.

2. After initially reporting to the probation office, you will receive instructions from the court or the probation officer about how and

when you must report to the probation officer, and you must report to the probation officer as instructed.

3. You must not knowingly leave the federal judicial district where you are authorized to reside without first getting permission from

the court or the probation officer.

4. You must answer truthfully the questions asked by your probation officer.

5. You must live at a place approved by the probation officer. If you plan to change where you live or anything about your living

arrangements (such as the people you live with), you must notify the probation officer at least 10 days before the change. If notifying

the probation officer in advance is not possible due to unanticipated circumstances, you must notify the probation officer within 72

hours of becoming aware of a change or expected change.

6. You must allow the probation officer to visit you at any time at your home or elsewhere, and you must permit the probation officer

to take any items prohibited by the conditions of your supervision that he or she observes in plain view.

7. You must work full time (at least 30 hours per week) at a lawful type of employment, unless the probation officer excuses you from

doing so. If you do not have full-time employment you must try to find full-time employment, unless the probation officer excuses

you from doing so. If you plan to change where you work or anything about your work (such as your position or your job

responsibilities), you must notify the probation officer at least 10 days before the change. If notifying the probation officer at least

10 days in advance is not possible due to unanticipated circumstances, you must notify the probation officer within 72 hours of

becoming aware of a change or expected change.

8. You must not communicate or interact with someone you know is engaged in criminal activity. If you know someone has been

convicted of a felony, you must not knowingly communicate or interact with that person without first getting the permission of the

probation officer.

9. If you are arrested or questioned by a law enforcement officer, you must notify the probation officer within 72 hours.

10. You must not own, possess, or have access to a firearm, ammunition, destructive device, or dangerous weapon (i.e., anything that

was designed, or was modified for, the specific purpose of causing bodily injury or death to another person such as nunchakus or

tasers).

11. You must not act or make any agreement with a law enforcement agency to act as a confidential human source or informant without

first getting the permission of the court.

12. If the probation officer determines that you pose a risk to another person (including an organization), the probation officer may

require you to notify the person about the risk and you must comply with that instruction. The probation officer may contact the

person and confirm that you have notified the person about the risk.

13. You must follow the instructions of the probation officer related to the conditions of supervision.

21a

Case 1:21-cr-00013-GNS-HBB

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Filed 04/15/25

Page 6 of 8 PageID #:

USDC KYWD 245B (Rev. 02/16) Judgment in a Criminal Case Sheet 3B - Supervised Release

Judgment-Page 6 of 8

DEFENDANT: Ramic, Mirsad

CASE NUMBER: 1:21-CR-13-GNS-1

SPECIAL CONDITIONS OF SUPERVISION

14. If deported, the defendant may not re-enter the United States without written permission of the Secretary of Homeland Security.

15. The defendant shall participate in a community-based mental health treatment program approved by the U.S. Probation Office. The

defendant shall contribute to the Probation Office's cost of services rendered based upon his/her ability to pay as reflected in his/her

monthly cash flow as it relates to the court-approved sliding fee scale.

16. The defendant shall submit to the USPO conducting an initial computer inspection/search of the defendant's computer system(s),

which are subject to examination and monitoring, which may include retrieval and copying of all memory from hardware/software

and/or removal of such system(s) for the purpose of conducting a more thorough inspection. An officer may conduct a subsequent

search pursuant to this condition only when reasonable suspicion exists that the defendant is in violation of the court's computer

monitoring condition, or is in possession of child pornography, as defined in 18 U.S.C. § 2256(8). Any search must be conducted

at a reasonable time and in a reasonable manner.

17. The defendant will consent to having installed on computer(s) which are subject to examination and monitoring at the defendant's

expense, any hardware/software to monitor the defendant's computer use or prevent access to particular materials. The defendant

hereby consents to periodic inspection of any such installed hardware/software to ensure it is functioning properly. The defendant

shall warn any other third parties who use these computers that the computers may be subject to searches pursuant to this condition.

18. The defendant shall participate in and abide by the rules of the Computer Restriction & Monitoring Program.

19. The defendant shall cease any use or activity on any computer subject to examination and monitoring until the computer can be

processed by the Special Offender Specialist or designee, to comply with the monitoring ordered by the Court.

20. Unless required for employment, the defendant is prohibited from using any computer other than the one monitored by the U.S.

Probation Office.

21. The defendant shall provide the USPO with accurate information about the defendant's entire computer system (hardware/software),

all passwords used by the defendant, and the defendant's Internet Service Provider(s).

22. The defendant shall submit his or her person, property, house, residence, vehicle, papers, computers [as defined in 18 U.S.C. §

1030(e)(1)], other electronic communications or data storage devices or media, or office to a search conducted by the United States

Probation Officer. Failure to submit to a search may be grounds for revocation of release. The defendant shall warn any other

occupants that the premises may be subject to searches pursuant to this condition. An officer may conduct a search pursuant to this

condition only when reasonable suspicion exists that the defendant has violated a condition of their release and that the areas to be

searched may contain evidence of this violation. Any search must be conducted at a reasonable time and in a reasonable manner.

U.S. Probation Office Use Only

A U.S. probation officer has instructed me on the conditions specified by the court and has provided me with a written copy of this

judgment containing these conditions. For further information regarding these conditions, see Overview of Probation and Supervised

Release Conditions, available at: www.uscourts.gov.

Upon a finding of a violation of probation or supervised release, I understand that the Court may (1) revoke supervision, (2) extend the

term of supervision and/or (3) modify the conditions of supervision.

These conditions have been read to me. I fully understand the conditions and have been provided a copy of them.

___________________________________

Defendant

_________________________

Date

___________________________________

U.S. Probation Officer/Designated Witness

_________________________

Date

22a

Case 1:21-cr-00013-GNS-HBB

Document 308

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Filed 04/15/25

Page 7 of 8 PageID #:

USDC KYWD 245B (Rev. 02/16) Judgment in a Criminal Case Sheet 5 - Criminal Monetary Penalties

Judgment-Page 7 of 8

DEFENDANT: Ramic, Mirsad

CASE NUMBER: 1:21-CR-13-GNS-1

CRIMINAL MONETARY PENALTIES

The defendant shall pay the following total criminal monetary penalties in accordance with the schedule of payments set forth

on Sheet 5, Part B.

Totals:

Assessment

$ 300.00

Fine

$ 25,000.00 – Ct. 3

Restitution

☒ The costs of investigation, prosecution, incarceration and supervision are waived due to the defendant's inability to pay.

☐ The determination of restitution is deferred until

. An Amended Judgment in a Criminal Case (AO 245C) will be entered

after such determination.

☒ Restitution is not an issue in this case.

☐ The defendant shall make restitution (including community restitution) to the following payees in the amount listed below.

Criminal debt may be paid by check or money order or may be paid online at www.kywd.uscourts.gov (See Online Payments

for Criminal Debt). Your mail-in or online payment must include your case number in the exact format of DKYW121CR000013-001

to ensure proper application to your criminal monetary penalty. If the defendant makes a partial payment, each payee shall receive an

approximately proportioned payment, unless specified otherwise in the priority order or percentage payment column below. However,

pursuant to 18 U.S.C. § 3664(I), all nonfederal victims must be paid in full prior to the United States receiving payment.

Priority Order

** Total

Amount of

Or Percentage

Name of Payee

Amount of Loss

Restitution Ordered

Of Payment

☐ If applicable, restitution amount ordered pursuant to plea agreement. . . . . $

☐ The defendant shall pay interest on any fine of more than $2,500, unless the fine is paid in full before the fifteenth day after the

date of judgment, pursuant to 18 U.S.C. 3612(f). All of the payment options on Sheet 5, Part B may be Subject to penalties for

default and delinquency pursuant to 18 U.S.C. 3612(g).

☐ The court determined that the defendant does not have the ability to pay interest and it is ordered that:

☒ The interest requiremen.t is waived for the

☐ The interest requirement for the

☒ Fine and/or

☐ Fine and/or

☐ Restitution

☐ Restitution is modified as follows:

* Findings for the total amount of losses are required under Chapters 109A, 110, 110A, and 113A of Title 18, United States Code, for

offenses committed on or after September 13, 1994 but before April 23, 1996.

23a

Case 1:21-cr-00013-GNS-HBB

Document 308

4725

Filed 04/15/25

Page 8 of 8 PageID #:

USDC KYWD 245B (Rev. 02/16) Judgment in a Criminal Case Sheet 6 - Schedule of Payments

Judgment-Page 8 of 8

DEFENDANT: Ramic, Mirsad

CASE NUMBER: 1:21-CR-13-GNS-1

SCHEDULE OF PAYMENTS

Having assessed the defendant's ability to pay, payment of the total criminal monetary penalties shall be due as follows:

☒ Lump sum payment of $25,300 due immediately, balance due

☐ not later than

, or

☒ in accordance with E below

☐ Payment to begin immediately (may be combined with C, D, or E below); or

☐ Payment in

☒ Special instructions regarding the payment of criminal monetary penalties:

(E.g. equal, weekly, monthly, quarterly) installments of $

Over a period of

(E.g. months or years) year(s) to commence

(E.g., 30 or 60 days)

after

The date of this judgment, or

(E.g. equal, weekly, monthly, quarterly) installments of $

Over a period of

(E.g. months or years) year(s) to commence

(E.g., 30 or 60 days)

after

Release from imprisonment to a term of supervision; or

Any balance of criminal monetary penalties owed upon incarceration shall be paid in quarterly installments of at

least $25 based on earnings from an institution job and/or community resources (other than Federal Prison

Industries), or quarterly installments of at least $60 based on earnings from a job in Federal Prison Industries

and/or community resources, during the period of incarceration to commence upon arrival at the designated

facility.

Upon commencement of the term of supervised release, the probation officer shall review your financial

circumstances and recommend a payment schedule on any outstanding balance for approval by the court. Within

the first 60 days of release, the probation officer shall submit a recommendation to the court for a payment

schedule, for which the court shall retain final approval.

Unless the court has expressly ordered otherwise in the special instructions above, if this judgment imposes a period of

imprisonment, payment of criminal monetary penalties shall be due during the period of imprisonment. All criminal monetary

penalties, except those payments made through the Federal Bureau of Prisons Inmate Financial Responsibility Program, are

to be made to the United States District Court, Gene Snyder Courthouse, 601 West Broadway, Suite 106, Louisville, KY 40202,

unless otherwise directed by the Court, the Probation Officer, or the United States Attorney.

The defendant shall receive credit for all payments previously made toward any criminal monetary penalties imposed.

☐ Joint and Several

Defendant and Co-Defendant Names and Case Numbers including defendant number), Total Amount, Joint and Several

Amount, and corresponding payee, if appropriate.

☐ The defendant shall pay the cost of prosecution.

☐ The defendant shall pay the following court cost(s):

☐ The defendant shall forfeit the defendant's interest in the following property to the United States:

Payments shall be applied in the following order: (1) assessment, (2) restitution principal, (3) restitution interest, (4) fine principal, (5)

community restitution, (6) fine interest, (7) penalties, and (8) costs, including cost of prosecution and court costs.

24a

Case: 25-5392

Document: 69

Filed: 06/01/2026

Page: 1

Case No. 25-5392/25-5471

UNITED STATES COURT OF APPEALS

FOR THE SIXTH CIRCUIT

ORDER

UNITED STATES OF AMERICA

Plaintiff - Appellee Cross-Appellant

MIRSAD RAMIC

Defendant - Appellant Cross-Appellee

BEFORE: GIBBONS, THAPAR, LARSEN, Circuit Judges;

Upon consideration of the petition for rehearing filed by the Defendant - Appellant CrossAppellee,

It is ORDERED that the petition for rehearing be, and it hereby is, DENIED.

ENTERED BY ORDER OF THE COURT

Kelly L. Stephens, Clerk

Issued: June 01, 2026

25a

Appendix C

Case 1:21-cr-00013-GNS-HBB

Document 311

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Filed 04/22/25

Page 1 of 59 PageID #:

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF KENTUCKY

BOWLING GREEN DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

vs.

MIRSAD RAMIC,

Defendant.

) Case No. 1:21-CR-13-GNS

)

) April 14, 2025

) Bowling Green, Kentucky

*****************************************

TRANSCRIPT OF SENTENCING HEARING

BEFORE HONORABLE GREG N. STIVERS

UNITED STATES DISTRICT CHIEF JUDGE

*****************************************

APPEARANCES:

For United States:

Joshua D. Judd

Christopher C. Tieke

U.S. Attorney's Office

717 West Broadway

Louisville, KY 40202

Kevin C. Nunnally

U.S. Department of Justice

NSD/CTS

950 Pennsylvania Avenue N.W.

Washington, DC 20530

[Defendant present.]

Transcriber:

Terri L. Horton, RMR, CRR

Official Court Reporter

133 U.S. Courthouse

501 Broadway

Paducah, KY 42001

Proceedings recorded by digital recording. Transcript produced

by computer from audio recording that the Court provided to

transcriber.

26a

Appendix D

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APPEARANCES (Continued):

For Defendant:

Scott T. Wendelsdorf

Western Kentucky Federal

Community Defender, Inc.

629 Fourth Avenue, Suite 200

Louisville, KY 40202

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(Begin proceedings in open court.)

DEPUTY CLERK:

Case Number 1:21-CR-13, United States

of America vs. Mirsad Ramic.

We're here this morning for a

sentencing hearing.

MR. JUDD:

represent the United States.

Tieke.

the Department of Justice, National Security Division.

Martin, he's with the FBI.

MR. WENDELSDORF:

Good morning, Your Honor.

He's an Assistant U.S. Attorney.

Kevin Nunnally from

Good morning, Your Honor.

Wendelsdorf for the defendant.

also Mr. Ramic, who is seated to my right.

THE COURT:

With me at counsel table is Chris

Josh Judd.

Andy

Scott

Chad Carter from my office and

All right.

Mr. Wendelsdorf, have you and

Mr. Ramic had a chance to review the presentence investigation

report, including any revisions?

MR. WENDELSDORF:

We have gone over the PSR.

Objections were made, Your Honor, and they're discussed -- the

operative ones are discussed in my sentencing memorandum.

THE COURT:

to be heard on at this time?

All right.

MR. WENDELSDORF:

Well, I know Your Honor has read the

sentencing memorandum --

THE COURT:

MR. WENDELSDORF:

Which of those would you like

Yes.

-- and I don't see any utility in

reading it back to Your Honor.

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But I think the pivotal issue here is the application of

3A1.4.

this case.

again, I don't want to go through the whole thing again because

I know Your Honor is aware of our argument.

3A1.4 does not apply in this case.

That has the most significant impact on sentencing in

It's our position, as we set out in detail -- and,

But we believe that

And this case is unique, as we point out.

There are three

ways to commit a violation of these statutes, and each of those

three ways requires specific knowledge.

the organization that a person aids is a designated foreign

terrorist organization by the Secretary of State; two, that it

engages in terrorist activity; or that it is a terrorist

organization.

Specific knowledge that

It's -- the first one is the most important.

There is an

argument that might be made that knowingly supporting a foreign

terrorist organization may imply an intent to influence the

United States.

designated foreign terrorist organization is that the terrorist

activity or terrorism of the organization threatens the security

of the United States nationals or the national security of the

United States.

does apply to a foreign terrorist organization.

Why?

Because one of the elements of being a

That does not apply to the other two prongs.

What makes Mr. Ramic's case unique is that we believe he was

not convicted of joining ISIL knowing it to be a designated

foreign terrorist organization.

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As Your Honor will recall from

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the trial, it was conclusively shown that the designation of

ISIL could not have been known to Mr. Ramic at the time that he

left the United States and joined ISIL in Syria.

the jury found that he had the other two prongs but not that

most important one in my view.

Now, granted,

The government conceded the point, Your Honor will recall,

in closing arguments, saying we can't prove that he knew ISIL

was a designated foreign terrorist organization, but we don't

have to.

these over here.

Don't convict him on those grounds.

Convict him on

That makes all the difference for the application of 3A1.4.

As we point out, 3A1.4 requires at the very least that the

activity be intended to and actually does influence a government

or retaliates against a government.

"government."

The operative word here is

Now, the PSR lists one government in this matter as being

influenced by the defendant.

paragraph 23, the PSR says, "At the time of their arrival, Syria

was in the throes of a civil war among several belligerents.

ISIS fought a war against two enemies on two fronts:

military forces under the," quote, "legitimate government led by

Syrian President Bashar al-Assad and against the Kurdistan

Workers' Party," or PKK, "a separatist militant organization

designated as a foreign terrorist organization by the U.S.

government."

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In paragraph 12 -- excuse me,

against

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And then again on paragraph 49, the PSR said that Mr. Ramic

"had reason to believe that ISIS would utilize his faculties and

personal efforts to commit or assist in the commission of

violent acts against the enemies of ISIS," and these are

delineated in the PSR.

Bashar al-Assad and the Kurdistan Workers' Party (PKK) or both

the Syrian government and the PKK."

"The Syrian government led by President

And then again in paragraph 50 that 3A1.4 is applied

because, quote, the defendant's offenses were calculated to

influence or affect the conduct of a foreign government (Syria)

by intimidation or coercion.

The problem for the government here -- and I guess I

reference for Your Honor -- is that Syria -- Assad's Syria,

Assad's forces were not the government.

detail in our sentencing memorandum on what a government is.

The short tour is an organization or a group or a movement is a

government if the President of the United States says that it

is, and if the President of the United States says that it's

not, then it is not a government.

And we go into great

And that is the case here.

We show conclusively in our sentencing memorandum that at

the times relevant to this case, the regime of Bashar al-Assad,

who himself is just another terrorist, was just another

terrorist organization.

Obama as the legitimate government of Syria.

the Syrian Opposition Coalition that was recognized.

He was not recognized by President

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In fact, it was

And, of

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course, Mr. Ramic did nothing to counter them.

fighting the same people.

Now --

They were

THE COURT:

The enemy of my enemy is my friend; right?

It's not a government.

MR. WENDELSDORF:

THE COURT:

MR. WENDELSDORF:

Usually.

I remember thinking that during the trial.

Yes.

But clearly the -- and the government's not alleging that

the PKK is a government.

government, and he was not a government.

conclusive, absolutely conclusive.

that the President of the United States did not recognize it as

such, closed their embassy, kicked them out of the country,

recognized the SOCC, let them open an embassy.

alone in this.

the SOCC and not Assad.

Question then.

But they are alleging that Assad was a

And that is

Because it was very clear

And he wasn't

Great Britain, France, other nations recognized

What government was impacted by Mr. Ramic's

conduct?

Now, this trial took place ten months ago.

Ten months ago.

And the deadline for objecting to the preliminary PSR was seven

months ago.

ago.

government was impacted by Mr. Ramic, the government of Syria.

The government did not object to that finding, did not object to

The final PSR was filed in this case 2.5 months

Throughout that whole thing, the PSR said that only one

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that timely, did not object to it when the final PSR was served.

They just stick a little footnote in there in their sentencing

memorandum for the first time saying, "Oh, by the way, we also

think the United States was also impacted."

the finding in the PSR, and the time to object is over.

it's too late in the day now for the government to walk in here

and change its theory of the case.

Well, that's not

And

So to answer Your Honor's question, I think the pivotal

issue in this matter is the application of 3A1.4.

We don't

think it applies.

what we are faced with is a total offense level of 28 instead of

40 and a criminal history category of I instead of VI, and this

leads to a guideline sentencing range of 78 to 97 months.

And if it doesn't apply, as we argued, then

Now, as the PSR itself recommends, we are asking the Court

to either vary or depart according to 5K2.23 or 5K2.0(a)(2) to

adjust Mr. Ramic's sentence in this case with a discharged term

of imprisonment he has already served for related offenses in

Turkey.

And as we pointed out -THE COURT:

Let me stop you right there,

Mr. Wendelsdorf.

MR. WENDELSDORF:

Yes, sir.

THE COURT:

I would like to hear from Mr. Judd

Yeah.

on this issue of the argument that the terrorism enhancement

doesn't apply --

MR. WENDELSDORF:

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Yes, sir, of course.

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THE COURT:

-- because Mr. Ramic's conduct was not

intended to influence the conduct of government.

MR. JUDD:

With Your Honor's permission, Mr. Tieke

would address the Court on that issue.

THE COURT:

All right.

MR. TIEKE:

Judge, I think that there's -- and I'm

going to do my best to walk through it and not rehash much of

the evidence that the Court heard.

But I think as a baseline the argument is procedurally

flawed because it assumes that you, Your Honor, are only limited

to that section of the PSR that says Syria, where -- and I'll

address the other points later, but that you're only limited to

paragraph 50.

conduct at sentencing, it can rely on the evidence that's found

to have -- the words are some minimum indicia of reliability

that you can rely on.

276 F.3d 884.

may rely on any competent evidence in the record as long as

there's some minimum indicia of reliability.

You're not.

The Court can rely on relevant

That case is United States v. Hough,

That's a Sixth Circuit case.

The district court

And without rehashing every single piece of evidence that

the Court heard at trial, I think that collectively much of the

evidence that was presented at trial included the defendant's

knowledge about what his actions were doing.

start -- if I can have the ELMO.

actual enhancement and then the reference that it makes to the

34a

And so I'll

I think that to start with the

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statute would be helpful.

Oh, I've got to turn it on.

I'm sorry.

There we go.

So there's the enhancement.

If the offense is a felony and

involves or was intended to promote the federal crime of

terrorism, and then you reference the statute.

And so there -- so the federal crime of terrorism is defined

as calculated to influence -- is calculated to influence or

affect the conduct of government by intimidation or coercion, or

to retaliate against government conduct.

the statutes, which I don't think there's any dispute about the

second part because he was convicted of the enumerated

terrorism.

And then (B) lists all

THE COURT:

Sure.

MR. TIEKE:

So we're only really looking at is

calculated to influence the conduct of a government.

And so, first, the argument is legally flawed for a number

of reasons.

uses the word "government."

recognized by the United States of America."

It assumes that that government -- the statute just

THE COURT:

It doesn't say "government

Of course it doesn't.

So what am I

supposed to do?

shouldn't I? -- or Black's Law Dictionary in the absence of a

definition?

Look at Merriam-Webster's dictionary --

I mean, that's what I did.

MR. TIEKE:

Well, I don't even think that the Court

needs to consider whether -- you should look at the word for

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government.

But Mr. Ramic's actions clearly indicate an intent

to affect not just the United States but other countries as

well, and that evidence was presented ad nauseam at trial.

And, frankly, his own actions in terms of joining ISIS,

flying to join ISIS, there's a general understanding, I think

Dr. Vidino testified, about what ISIS was doing in terms of

affecting governments through its terrorism activity.

Mr. Ramic's own social media and his communications with his

co-defendants contain ample evidence that the Court could find

by a preponderance that his actions are intending to influence

governments.

But

For example, we have, if the Court will recall this, social

media discussing, you know, families of fallen veterans with the

United States flag back there.

post, social media.

"Are you ready for a joint mission to make

more of them fall?

#IS.

This was a social media post celebrating exactly what ISIS is

doing.

And this was accompanied by a

#Iraq.

#US," with the American flag.

There is this post, if the Court will recall from trial,

where Mr. Ramic is discussing the daughters of the President of

the United States being sold into slavery.

will recall, Malia Obama was 16 years old and Natasha Obama was

13 years old at the time of the posts.

And if the Court

We have discussions about the differences between diameter

from different planes, allied forces that were in the region

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where Mr. Ramic was actually actively fighting, not just the

United States.

you know, two -- the "Rafidah," or the rejectors, "the Shia of

Iraq, you have two options.

recognition.

references Egypt.

I mean, we have other Twitter posts mentioning,

Sunnah or die."

So there's a

And then, of course, this post that we -This is the one that we discussed at trial.

THE COURT:

Mr. Tieke, wouldn't you agree that at

trial all the evidence really was that Mr. Ramic -- in terms of

his actions, they were all directed towards his efforts to join

ISIS as a fighter to help liberate this caliphate in Eastern --

Northeastern Syria; right?

I mean, refresh me if I'm mistaken, but I don't remember any

evidence that Mr. Ramic intended or was involved in any shape,

form, or fashion with random acts of violence against innocent

populations, that -- at least this is the overwhelming

impression I got at trial, is he was wanting to go fight a war

so that this band of Sunni Muslims would be able to impose

sharia law on their own country, their own territory.

that's what I took away from the trial, but not that he -- not

that any of these efforts were directed towards the Obama

children or that he was -- intended to be a suicide bomber.

In fact, what I recall is he signed up with the army.

I mean,

When

he got to Syria, he signed up with ISIS, and they took

information from him just like they did -- just like you would

in many armies.

It seemed to have been organized largely as

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what I would think of as a conventional army, not a -- not

intending to engage in random, senseless acts of violence

intended to terrorize the general population, but to attack and

control that area of Syria.

And so, frankly, the PSR, when it said that the ISIS forces

that Mr. Ramic joined were fighting the PKK and the Syrian

government, that's exactly what I remember at trial.

frankly taken aback by the argument that the Syrian government

wasn't a government.

another terrorist organization.

But the PKK clearly was not.

And that's what I mentioned earlier.

I was

That was

During the trial, the

one thing that really -- I mean, I sit up here and take notes.

I remember scribbling down, "The enemy of my enemy is my

friend," in that these ISIS terrorists -- it's a foreign

terrorist organization, so they were terrorists by definition.

But they weren't fighting the United States.

for their own caliphate.

and the Syrian government.

They were fighting

They were fighting the Kurds, the PKK,

So here's what I did -- and I frankly think this is the

answer, is when you're looking at the enhancement based upon an

intent to influence or affect the conduct of government, it

doesn't say -- if they intended that to say "government

recognized for diplomatic purposes by the United States," that's

what it would have said.

Merriam-Webster.

But government -- I looked up

"Government" is defined as the body of persons

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that constitutes the governing authority of a political unit or

organization.

then Black's Law Dictionary has essentially the same definition.

The government of Syria.

I mean, to me -- and

And because the statute doesn't indicate any other

definition, it seems that clearly the government of Syria

satisfies the requirement that the offense conduct was intended

to influence or affect the conduct of government, that being the

government of Syria.

So that's how I got to -- I mean, when I read the

defendant's sentencing memo, I was -- like I said, I was -- I

was surprised.

taking a very specific, you know, quote from the U.S. Supreme

Court, I think that if the statute was intended to have a more

specific definition rather than a general definition, how it

is -- just the plain ordinary meaning of the word, Congress

would have specified.

MR. TIEKE:

the beginning.

would qualify.

It seemed like a great argument, except that

Right.

And that's what I brought up at

It doesn't specify that.

The Syrian government

And, Your Honor, some of the testimony -- Dr. Vidino

testified at trial about this very issue in terms of what Syria

looked like at the time, regardless of what portions Assad

controlled or not.

Dr. Vidino testified that Syria was still a recognized

government and country at that time.

But he even then -- you know, at least

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My point in bringing up all these other instances of

Mr. Ramic's knowledge was that I think when you join ISIS, you

have an understanding that it's attempting to -- he was in the

sector involving Syria, but the entire goal of ISIS would be

to -- would be to essentially take that viewpoint and conquer as

much territory.

that his actions, in terms of what he did, it affected that

portion, but he also, I believe, based on much of the evidence

in terms of his social media posts, had a broader understanding

of the effect of ISIS's activities on other countries as well.

Syria.

So the fact that -- I would agree with you in

This is another -- I mean, another example here

where this demonstrates a broader understanding.

"... air

strikes will not defeat," this broader idea of ISIS's effects on

other governments, not just the immediate one that he was

involved in in terms of his actions in Syria.

So my point in showing those was to demonstrate that his

knowledge seems to be broader than just his own narrow scope of

what he was doing in Syria, which would have qualified, but

also, you know, these other posts tend to show that ISIS

generally and being a fighter for ISIS is calculated to

influence or affect the conduct of government.

but other ones as well.

THE COURT:

Not just Syria,

Well, I think in terms of general intent

versus specific intent, to me -- like I said, the way I read the

3A1.4 and the definition that's incorporated from

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18 U.S.C. 2332b(5), I think that that's satisfied and that

terrorism enhancement does apply.

MR. TIEKE:

Thank you, Your Honor.

THE COURT:

All right.

MR. WENDELSDORF:

Mr. Wendelsdorf, next.

That bring up then -- we

respectfully disagree, of course, but I understand that.

how these things go.

That's

Is Your Honor agreeing with me, however, that the only two

entities that were directly impacted by Mr. Ramic's behavior

were the forces under the command of Assad and the PKK, as set

forth in the PSR?

Was Your Honor giving me that?

THE COURT:

That was my recollection of the evidence.

MR. WENDELSDORF:

Thank you, Judge.

THE COURT:

And so if you're right about the

Yes.

limited definition you came up with, you know, you find a

definition of "government," but I don't think that's what

Congress intended here.

MR. WENDELSDORF:

THE COURT:

MR. WENDELSDORF:

Very good.

Frankly, I don't.

I understand, Your Honor.

Thank

you.

Which then brings us to an issue which I'd hoped we wouldn't

have to get to, and that is the criminal history category.

believe that a criminal history category of VI substantially

overrepresents the true criminal history of this defendant and

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for the reasons we set forth in our sentencing memorandum.

Again, I need not read it back to the Court.

that Mr. Ramic's actual criminal history was a very, very old

traffic offense, that he was under intense surveillance by the

FBI for years.

committed any other criminal offenses or violent offenses other

than that one traffic offense.

individual.

But we all know

He lived in this country for years, never

This is not a Category VI

Now, the Category VI in this case is applied as a result of

the enhancement, but just like everything else in the

guidelines, it is advisory only.

Court.

memorandum, the rationale behind the criminal history categories

and why we have criminal history categories and how we calculate

criminal history categories, if you go to that instead of just a

one size fits all, I think Your Honor would agree with us this

overrepresents his true criminal history category.

very least, we ask the Court to downward depart to a criminal

history category of I.

It is not binding on the

And if you look, as we cite in our sentencing

MR. JUDD:

And at the

Judge, we obviously would defer to the

guideline enhancement that says the application should be

Category VI, and that's what the guidelines impose for

application of the terrorism enhancement in this case.

it makes sense.

significant criminal activity, and the guidelines follow that as

We think

Terrorism was specifically designated as

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well.

THE COURT:

And for the guideline purposes, yes, I'm

going to accept the criminal history category of VI.

what the guidelines instruct.

What about to me seemed to be a late developing argument

regarding the mandatory minimum sentence of ten years?

That's

MR. WENDELSDORF:

I think we're in agreement on that,

Judge.

THE COURT:

Okay.

MR. WENDELSDORF:

Initially, the government took the

position that there was a mandatory minimum prison sentence of

ten.

indicated to the probation officer that he agrees with our

argument.

We objected to that in the record.

This is a very poorly worded statute.

I believe Mr. Tieke

I mean, it's abysmal.

But I think it's very clear that what it says is, is that anyone

who violates it shall be punished by a fine or a prison sentence

of ten years or both.

more traditional mandatory minimum sentences which make it very

clear that there shall be a prison sentence and it shall be no

less than this.

States agrees with me -- is that you are not obligated by the

statute to impose a ten-year sentence, but if you impose a

prison sentence on Count 3, there's nowhere to go but ten years.

But what that means is that in fashioning what Your Honor

And in my objection, I referenced other

Our position is -- and I believe the United

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believes to be an appropriate overall sentence that Your Honor,

for example, could sentence Mr. Ramic to seven years on Count 1,

seven years on Count 2, and a fine on Count 3 and thereby giving

him a sentence of seven years.

Court impose a ten-year mandatory minimum.

There's no requirement that the

And I think we're in agreement.

MR. TIEKE:

That's right, Judge.

If the Court were to

impose a sentence of imprisonment on Count 3, it would have to

be ten.

So effectively it establishes a mandatory minimum, as that

word's colloquially used.

on Count 3, it has to be ten years.

MR. WENDELSDORF:

So I would agree with Mr. Wendelsdorf on that point.

So if there's a prison term sentence

But there doesn't have to be a

prison sentence.

MR. TIEKE:

No.

There could be or a fine, as

Mr. Wendelsdorf said, or both.

chooses to impose a sentence of imprisonment with respect to

Count 3, it would have to be ten years on that count.

MR. WENDELSDORF:

MR. TIEKE:

Yes.

THE COURT:

All right.

MR. WENDELSDORF:

And so -- but if the Court

I think we're in agreement.

And then the only other argument,

Judge -- and I spent quite a bit of time on this -- would be the

3553(a)(2) factors, and I believe my sentencing memorandum

speaks for itself on that.

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We believe that a sentence substantially below that

recommended by the PSR and by the guidelines is the appropriate

sentence in this matter, assuming, as the Court has done,

applies the 3A1.4 enhancement that ups the ante.

again, all that leaves us with is a recommended sentencing

range, and the guidelines, of course, are only one of the many

factors that the Court must consider in applying a rational

sentence in this matter.

sentencing memorandum, we believe that those indicate and compel

a substantially lesser sentence than that recognized by the

guidelines.

But then

And for the reasons outlined in our

And then, lastly, whatever sentence the United States -- the

Court decides is the appropriate sentence in this case, we have

asked that the Court vary or depart downward from that sentence

by at least 68 months to adjust for the discharged term of

imprisonment that Mr. Ramic has already served, for the reasons

outlined in our sentencing memorandum.

of the barbaric conditions of that incarceration that the 68

months would be the minimum amount of time that the Court should

downward depart.

And we believe because

So I think first the Court should decide that under 3553

this is the appropriate sentence and then downward depart, as

suggested by the PSR itself, by no less than 68 months.

And I'm done.

Thank you.

THE COURT:

Two things.

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So, first, you do agree,

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then, that under the guideline, as I have found with the

terrorism enhancement, the guideline range is 360 months to the

statutory maximum on the three charges of 600 months?

MR. WENDELSDORF:

that's correct, Your Honor.

THE COURT:

Correct?

According to Your Honor's rulings,

Okay.

Very well.

And with regard to Count 3, if there is a sentence imposed

on Count 3, it has to be ten years.

there can be no credit given for the time --

MR. WENDELSDORF:

but I understand what you're saying.

THE COURT:

And against that ten years,

Oh, I believe there can be, Judge,

Okay.

Well, that's what I want to know.

Then I would like, Mr. Judd, for you to address that.

there's a sentence under Count 3 that has to be ten years --

MR. JUDD:

Yes, sir.

THE COURT:

-- does the Court have the latitude to

count against that ten years -- and I've got 67 months is what I

thought the PSR said.

MR. WENDELSDORF:

THE COURT:

Sixty-seven months for time in the Turkish

MR. JUDD:

I think that time is correct.

I'll concede the month.

prison.

The 67

months is five years and six months.

THE COURT:

Right.

MR. JUDD:

Your question is -- reading the statute is

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shall impose a fine or imprisonment of ten years or both.

you have -- if you give a prison sentence on it, it's the

position of the United States you don't have any discretion

except to give ten years on that.

THE COURT:

A hundred and twenty months with no

MR. JUDD:

That's correct.

THE COURT:

That's what I thought.

credit?

(Simultaneous speaking not reportable.)

MR. JUDD:

-- credit another sentence, another charge,

Count 1 or 2.

THE COURT:

MR. WENDELSDORF:

Okay.

Yes.

If I understand what Your

Honor is saying, then, yes, the credit could be applied to

Count 1 and Count 2.

MR. JUDD:

We're going to argue against it from the

government's perspective.

THE COURT:

I understand.

But if there's a term of imprisonment under Count 3, credit

for that 67 months cannot be given against the mandatory 10-year

sentence?

MR. JUDD:

That would be the position of the United

THE COURT:

That's what I thought.

MR. JUDD:

Yes.

States.

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MR. WENDELSDORF:

But we would disagree with that.

Compare that to the other statutes I cite in my response, and

this is where -- for example, in drug cases or sex offenses.

Shall be imprisoned for no less than X years.

underneath that.

Puts a floor

Now, I would concede that in a situation like that, you

can't give a credit under -- for a discharged term, but we don't

have that language here.

I think everyone would agree with that.

detract from it.

government that that ten years, if you imply -- if you apply a

prison sentence, cannot be subject to reduction because of

Turkey, clearly any sentence in Counts 1 and Count 2 can.

This is a very poorly worded statute.

But I think you can

But even if Your Honor agrees with the

And, lastly, keep in mind, Judge, that this is three charges

coming out of the same course of conduct.

does, we would hope that Your Honor would run these terms

concurrent with each other.

THE COURT:

All right.

MR. JUDD:

Yes.

Whatever the Court

Mr. Judd?

I would like the opportunity to

address the Court for the 3553(a) factors --

THE COURT:

Sure.

MR. JUDD:

-- dealing with Mr. Ramic.

As the Court knows, Mr. Ramic's history goes way back in

this case to 2009 when he was a naturalized citizen in the

United States where he became a citizen.

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month later, he obtained his passport, which we believe is his

intent to travel outside the United States.

later, he had purchased a ticket and traveled to Yemen.

believe at the time Yemen was, you know, basically infiltrated

by Al-Qaeda at the time.

Less than a year

What we know about Mr. Ramic's intent at the time was later

when the FBI interviewed him on his way back.

him in Germany, they interviewed him in Philadelphia, and they

subsequently interviewed him in Bowling Green.

at the time under suspicious circumstances is what initiated the

case.

diligence, to try to make sure that the community was safe from

somebody that may have the intent to engage in terrorism.

Rightfully so.

They interviewed

And his travel

And the FBI did its job, its due

And so they opened a case on him.

He was interviewed three

times.

Mr. Ramic knew what the FBI was investigating.

trying -- they were trying to ferret out whether he had intent

to engage in terrorist activity in a foreign country.

uses its resources.

try to ferret out what his true intent is.

get into a man's mind that you have to use the techniques that

law enforcement has at their ability to use.

And the significance of those interviews is that

They knew he was

The FBI

They engage a confidential human source to

It's so difficult to

So they engaged a confidential human source, and they also

used an undercover FBI employee.

only place we can draw why he went to Yemen.

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And from that is really the

Al-Qaeda was very

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active in Yemen at the time.

And then he speaks to the FBI undercover on the platform

known as Authentic Tauheed, which is the Paltalk application, in

chat rooms that are operated by a known terrorist supporter,

Shaikh el-Faisal.

is becoming radicalized and consuming jihadist material inside

that platform, and it's not normal religious materials.

anti-Western rhetoric.

the sermon that he downloaded -- there were multiple sermons

that he had, but that one was specific.

was caught by the fact that they were talking about improvised

explosive devices, traveling, you know, to foreign countries to

engage in jihad.

And this is -- Ramic basically -- Mr. Ramic

It is

It is also, as the judge has seen from

And the United States

But the undercover from the FBI spoke to Mr. Ramic on the

platform, and Mr. Ramic said you have to basically lie about

your true intentions to travel to engage in jihad.

that when he was naturalized, instead of saying the oath of

allegiance, as so many people would love the opportunity to do

in the United States, he said the Shahadah and cursed the

kuffar.

believe the same thing as Mr. Ramic.

draws the understanding that Mr. Ramic traveled for reasons

other than to study at the Dar al Mustafa school located in

Yemen.

He also said

And the kuffar basically stands for someone who doesn't

So from that, the FBI

So between 2011 through 2012, Mr. Ramic engaged in those

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communications with the online undercover from the FBI that

testified, from the CHS that had testified.

search, the FBI was able to examine Mr. Ramic's Compaq Presario

computer, where they found evidence of his use of Paltalk,

basically the requirements of jihad sermon.

interest in Osama bin Laden, other known terrorist leaders, and

Shaikh el-Faisal, who was a known jihadist that encouraged

people to engage in acts against the West.

And through a

There was obvious

In 2014 was when Mr. Ramic, Alkhalaf, and Alnwfal decided to

plan and execute their travel to Istanbul, Turkey.

note for the Court that Mr. Ramic had an end leg ticket that

would result in him being able to travel successfully back to

Bosnia.

the time would have taken him back to where he was from.

would have had the opportunity not to engage in terrorism, not

join ISIS, receive training, and actually fight a war in Kobani.

I would just

The end leg of his ticket that he chose not to take at

Likewise, his two co-conspirators who shared his same

beliefs had end tickets in Saudi Arabia.

Istanbul.

close to the Syrian border, of which they traveled to Tal Abyad

and basically enlisted in ISIS as military fighters.

some choices.

They met up in

They paid cash for a ticket to Gaziantep, a town

They had

They chose to fight and enlist.

As the Court knows, later -- I would just note the travel is

unique.

It's not like he flew straight to Istanbul.

concealed the last leg of their trip.

51a

They

Some tradecraft involved.

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They paid cash.

They were clearly avoiding detection.

THE COURT:

No.

There's no question.

No.

There was

a conspiracy to get to whatever that little town was in Turkey

where he crossed over.

great detail.

question that Mr. Ramic left the United States with his two

buddies from Western and they wanted to go fight this war.

Yeah.

You-all laid that out with -- in

I remember that extremely well.

There's no

MR. JUDD:

Yes, sir.

THE COURT:

And that's what they did.

MR. JUDD:

Just to point out a few things throughout

the case that I would like just to highlight for the Court.

You know, he was then transported to Al-Tabqa, which is

close to Raqqa, which was the provincial capital of ISIS.

at that time he received his military training, mostly

involving, you know, Islamic religious training as well as

weapons training.

It's

If you remember, Mohammed Das had testified that's where he

met Mr. Ramic.

that -- he used a term that I really wasn't familiar with and I

think my colleagues either.

to our attention that -- basically he explained that that meant

he was extreme and violent.

documented his Kik username, abuhazimi, and who he was and what

he was doing at the time.

But in his testimony, Mohammed Das had testified

He used the term "ghulu."

Brought

As you remember, Mr. Das had

Later, Ramic begins around July of 2014 using Twitter and

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posting many of the things that my colleague, Mr. Tieke, had

shown the Court.

the discovery that he had traveled with Alkhalaf and Alnwfal to

Syria to engage in jihad and to support ISIS.

And it was through that process that basically

THE COURT:

Let me ask you this, Mr. Judd:

The

trial's been ten months ago, and it was -- you know, there was a

lot of information.

Mr. Ramic engaged in any incriminate acts of violence against

innocent civilians for the purpose of creating terror in a

general population?

But was there any evidence produced that

And that -- to me, that's my conception of terrorism, and

that's -- I don't recall any of that.

whole holy war -- and not just holy war against the world but to

fight for this caliphate -- seems to be -- it seemed to be the

United States' theory of the case all along that that's what he

intended to do and that's what he did.

Again, it seemed this

And I know you-all included -- I remember the slides --

MR. JUDD:

Yes.

THE COURT:

-- that you included in your sentencing

memo that seemed to indicate support for some heinous acts.

know the beheadings of the Coptic Christians was referenced.

But I don't recall any evidence that Mr. Ramic had any

involvement in any activity like that.

MR. JUDD:

Kobani, Your Honor.

Well, he was involved in the assault of

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THE COURT:

Which was a battle fighting -- that was --

this is what I took from the evidence:

fighting for the creation of this caliphate.

MR. JUDD:

Yes.

That was a battle

I agree that he fought with ISIS, a

terrorist organization, to create a caliphate, but it's his

expression and his role as a propagandist for ISIS that he

expresses these violent ideas.

THE COURT:

So that was -- my question was:

Is there

any evidence that Mr. Ramic engaged in acts of indiscriminate

violence against -- what I would think of as an atrocity other

than engaging in battle as part of an organized armed force?

MR. JUDD:

I would say yes, Your Honor.

THE COURT:

Okay.

MR. JUDD:

I think the invasion --

THE COURT:

Please remind me what that was.

MR. JUDD:

I think the invasion on Kobani, the impact

on the Kurdish people, and forcing them in the invasion to

relocate.

Kurds perished during the invasion of Kobani, moved to Turkey,

and there was a human rights atrocity caused by ISIS.

be a caliphate, but they're a bunch of indiscriminate killers

who have targeted the West and each other to take over a

sovereign country to engage in terrorism.

And he fought on behalf of ISIS.

And a lot of them were killed.

of him --

54a

A hundred thousand

They may

And I don't have a picture

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THE COURT:

Right.

MR. JUDD:

-- burning somebody alive in a cage, but he

advocated for similar things using his postings on Twitter,

which is the Coptic Christians, you know, talking about the

airplanes, enslaving human beings, Natasha Obama.

about having slave girls clean his house.

caliphate that's focused on something -- increasing their land

holdings, but they also are a bunch of terrorists who engage in

violent activity for which he expressed his support for.

people that watched him.

with a weapon.

THE COURT:

governmental forces of Syria?

I do not have

I have people who saw him go to battle

This may be a

I do not -- I know the Judge's question.

He talks

But weren't they fighting the PKK and the

That -- again, that's what I recall.

That was the

impression I got from the evidence that was presented.

MR. JUDD:

Yes, but it does not stop there.

I don't

think it does.

I think the Western idea -- his association with Adnani, the

propaganda minister, where he says #Adnani, where they changed

their ideas from expressing people coming from foreign countries

to join to doing terrorist acts outside the United States.

Mr. Ramic's propaganda, his expressions of support are violent,

I believe.

burning somebody in a cage, but we think -- you know, he knew --

I don't have him, you know, pulling the trigger or

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everybody in 2014, before he went, knew that ISIS was engaged in

terrorist activities.

had to know it.

multiple times about it.

It was all over the news.

He would have

He already knew the FBI had talked to him

You know, I think that is terrorism and really goes to the

nature and circumstances of Mr. Ramic's offense, which is the

United States' focus in the sentencing factors for the criminal

activity.

he had multiple roles to fill for ISIS.

perspective, you know, is important.

arms, enlisting, training, all those things are accounted for

throughout his history.

You know, looking at his history going forward that

THE COURT:

And propaganda from our

Also, fighting, taking up

So the -- is the propaganda the messages,

whether it was WhatsApp or Instagram?

MR. JUDD:

These were Twitter messages.

THE COURT:

Twitter messages.

MR. JUDD:

Or Twitter postings.

THE COURT:

You know, I looked at the images that the

Excuse me.

United States included in its sentencing memo, and I couldn't

tell how many people those went to.

many followers.

tweets that he was sending to his buddies and not that he had a

million followers, that he was helping create a bigger movement.

It seemed to be more a chat between Mr. Ramic and his two

co-conspirators or his two buddies from Western.

Usually it will show how

My impression at trial was that these were

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MR. JUDD:

That's true.

There were messages between

them.

source, collected by the FBI, for anyone to see, for anyone to

view.

shut down.

Twitter in order to continue, you know, just popping out threats

or violent material.

THE COURT:

But the postings that are the focus in our memo are open

And, you know, ultimately his platform would have been

He opened up another, abuhazime with an E, on

But was there evidence presented on how

many people viewed those messages?

MR. JUDD:

No.

THE COURT:

Okay.

(Simultaneous speaking not reportable.)

THE COURT:

I was just kind of left, again, with the

impression that he -- there was an absence of an impression that

there were any significant number of followers that viewed

those -- that viewed those messages.

was presented at trial, and then when I looked back at the

images included in your sentencing memo, I also couldn't tell --

I mean, I'm not a big Twitter, Instagram person, but generally

when you see them, you see, oh, this has 13,000 views or 1,200

likes.

anyone, frankly beyond Mr. Ramic's two friends, who saw this

information.

I didn't see any.

I couldn't tell from what

I saw no indication that there was

And if you don't know, that's fine.

there's an absence.

But, again, to me,

There's an absence there of information

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that could very heavily impugn Mr. Ramic's involvement in going

to fight this war.

But -- and I think maybe the United States used the word

"propagandist" in its sentencing memo, and frankly that's the

part that kind of lost me, because I didn't -- no more of a

propagandist than somebody's teenage daughter or child -- I've

got daughters -- but that some college kid may send out a tweet

that ten of his or her fraternity brothers or sorority sisters

might see.

there were ten people that saw it.

I didn't even see that.

I didn't even see that

And they were -- I will give you this:

They were

inflammatory.

Mr. Ramic's mindset that he -- you know, the beheading of the

Coptic Christians on a beach, wherever that was, I mean, if you

ever saw an allusion to those images, it's kind of hard to

forget that.

support, the United States didn't make the connection with me on

that.

I mean, they certainly did give an insight into

But in terms of this crime of providing material

MR. JUDD:

Understood.

We certainly, you know, believe these show the intent of

Mr. Ramic and his support for them.

Certainly, you know, he

hashtags ISIS and makes violent rhetoric.

intent, Judge, and I think that's one of the points we wanted

you to take away.

had influenced or, you know, the world in which he was able to

Certainly shows his

We didn't really focus on how many people he

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reach.

THE COURT:

That really wasn't part of your case;

MR. JUDD:

No, sir.

right?

It certainly was not an element

we needed to prove, so we didn't really focus on it.

THE COURT:

Well, then so it's kind of hard for me to

take that into account when it's time to sentence.

MR. JUDD:

Well, I mean, they're his postings.

made them.

We think they're inflammatory.

That's the purpose

for us putting them in our sentencing memo.

Certainly show his

violent statements toward the President of the United States

daughters and his advocacy for taking up arms and identifying

dead soldiers by a pamphlet that's given to retired -- or

dead -- basically soldiers who died in combat's family.

think that is anti-U.S., we think that expresses his

understanding of what he's doing, and that's why we submitted it

to the Court.

And we

THE COURT:

Well, reprehensible, no doubt.

MR. JUDD:

And, Judge, I just have a few more points,

and then I'll sit down.

We are asking for a significant sentence for Mr. Ramic in

this case.

You know the facts of the case, the nature and

circumstances of the case, and this specific incident.

it's more than just him joining a caliphate to try to go to war.

I mean, I think he joined the idea of ISIS and what they were

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trying to achieve, and we would ask the Court to keep that in

mind, that this was a larger organization with a lot of goals

than just taking over a piece of land in ISIS territory.

think they wanted to expand, and certainly his tweets advocate

and show his state of mind when he's there.

specifically in Kobani.

Kurdish people in the community.

He takes up arms

Kobani's impact was significant for

And perhaps the most striking thing about Mr. Ramic is there

is no indication of any remorse for the criminal activity here.

There's no detachment from ISIS from him.

He was arrested under a false name in Turkey with a false

document.

that time period.

You sat through the trial.

He did leave ISIS.

We saw Mr. Ramic during

You know, there are aggravating circumstances here for

Mr. Ramic in that he is not just a person that intended to go,

that got caught at the airport.

his goal, which I think, based on his history, was a

long-standing desire of his to go support a foreign terrorist

organization that engages in jihad.

concern for the Court in this case, specifically for protection

of the public, protection of this community, and --

He actually was able to achieve

I think that should be a

THE COURT:

Let me ask you this, Mr. Judd --

MR. JUDD:

Yes, sir.

THE COURT:

-- with regard to protecting the public:

Mr. Wendelsdorf argues strongly that Mr. Ramic is going to be

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deported once his term of imprisonment ends.

impression that I can't consider that.

MR. JUDD:

I'm under the

Do you agree?

I don't think we know what's going to

happen with Mr. Ramic.

don't know the answer to whether he will conclusively be

deported.

You know, I think it's possible.

I don't think it's automatic.

We've consulted with DOJ on this as to whether he would

automatically be deported.

than that.

that is outside of the prosecution team's hands.

think any of it is automatic.

THE COURT:

No.

I think it's more complicated

There may be a denaturalization process.

All of

And I don't

Do you believe it's inappropriate for the

Court to consider that?

MR. JUDD:

Well, Judge, treading carefully, I would

ask the Court not to consider it because it's really not

relevant to what he did in this case.

protecting the public --

THE COURT:

And the idea of

Yeah, protecting the public.

That's the

whole thing.

MR. JUDD:

Because we don't know that it's going to

THE COURT:

Right.

MR. JUDD:

I don't think we know that it's going to

happen.

Somebody may pursue it.

And it's out of your hands; it's out of my hands.

61a

They may file the paperwork.

It's with

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some ALJ somewhere that would proceed on the factors on which

they understand, which I do not, and ultimately make a

determination.

things like that before, and it's based on facts that happened a

long time ago and the requirements.

But I think it's complicated.

I've looked at

But the point being we don't know and I don't think it's

automatic, and we would request the Court not to consider that

it be, you know, something that's absolutely going to happen

because we don't know that.

THE COURT:

I won't consider it at all.

I don't know

I do have an impression.

My impression

it's going to happen.

is that if there's ever somebody that would be appropriate for

deportation, it would be Mr. Ramic.

You know, he came to the United States.

He hated it.

He went, you know, to Syria.

wanted to leave.

too.

But like I said, I'm not going to consider it because I don't

know what's going to happen.

MR. JUDD:

I don't know where he's going to go.

He hated that

I'm assuming Bosnia.

We don't know whether Bosnia would take

him.

I don't know the answer.

so maybe that's an option.

I think he has dual citizenship,

We don't know.

But in conclusion, Your Honor, if I may, I mean, we're

asking the Court to focus on the nature and circumstances of

this offense and protecting the public and deterring individuals

who have been successful in their attempts to leave the country,

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go to ISIS, and fight.

Some of them are stopped at the airport.

That's not Mr. Ramic.

Mr. Ramic was able to get there, train,

effectuate his goals, and do the offense conduct that the

Court's familiar with.

and circumstances of the offense into account as well as

protecting the public and deterrence in this case.

So we'd ask the Court to take the nature

We would ask for a sentence on each count -- the first two

counts of 20 years, and then on Count 3, we would ask the Court

impose a sentence of 10 years, with a lifetime of supervised

release.

An important factor we'd ask the Court to consider is he has

not indicated any type of remorse.

There's nothing to indicate he's changed his viewpoints on what

he believes, and his belief is that ISIS and the caliphate were

expanding territory.

statements in his tweets.

this case, based on Mr. Ramic's behavior, is appropriate, and

we'd ask the Court to do so.

Mr. Ramic is a hard-liner.

He took up arms for them.

He made

And we think a serious sentence in

Thank you.

THE COURT:

Mr. Wendelsdorf?

MR. WENDELSDORF:

Two things, Your Honor.

Again, I

stand on my sentencing memorandum, but I just wanted to respond

to two points made by the government.

One is the perceived lack of remorse, the lack of rejection

of ISIS and its mentality.

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I'm somewhat constrained in what I

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can say on the public record because I would be quoting from

materials that are classified.

sentencing memorandum under seal -- and I'm sure Your Honor has

seen Exhibit C, which are communications from Mr. Ramic to

others following his leaving ISIS and being arrested in Turkey,

in which he repudiated ISIS.

However, I did include in my

He used the term "takfir" in responding to or in describing

ISIS leadership, and he had declared takfir on them, which is a

means of excommunication of one Muslim by another.

of accusing another Muslim of being an apostate.

course, in Islam, an apostate is a Muslim who has abandoned

Islam in thought or deed.

heresy, the strongest denunciation in Islam.

And, of

It's an accusation of blasphemy or

With the -- well, I won't even ask the United States to

agree to let me read these into the record.

them.

It's a way

Your Honor has seen

They're Exhibit C.

But this indicates a total repudiation by Mr. Ramic of ISIS

and its mentality and abandonment of its leadership.

referenced this in our sentencing memorandum that he saw the

hypocrisy and the lies of ISIS and repudiated them.

very, very similar to Mohammed Das and his change of attitude

once he saw the lies that ISIS had perpetrated.

This is

The second thing I'd like to comment on, it may or may not

be really relevant to sentencing, but it keeps coming up.

that is Mr. Ramic's supposed glee over the beheading of the

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Coptic Christians in Libya.

out, he did indicate a support for that outcome for those

people, although he did not participate directly or indirectly

in that.

As Your Honor correctly pointed

I would refer the Court to the sentence -- to the PSR.

isn't my spin.

probation officer's spin.

In paragraph 12:

naturalized U.S. citizen.

of Bosnia and Herzegovina in 1990, which was then an autonomous

province or constituent state of the former Socialist Federal

Republic of Yugoslavia.

This isn't the government's spin.

This

This is your

Mirsad Ramic is a Bosnian national and a

He was born in the Socialist Republic

Ramic spent his formative years in war-torn Bosnia during an

armed sectarian conflict commonly referred to simply as the

Bosnian War.

from about April 1992 to December 1995.

was marked by acts of ethnic cleansing and war crimes on behalf

of military forces or paramilitary groups against civilians.

These war crimes included genocide, mass rape, and the forceful

removal of ethnic minorities, such as Bosnian Muslims and

persons of other religious or ethnic backgrounds, at the hands

of military forces or those of paramilitary groups.

information and belief, Ramic's father, a Bosniak, died in an

event called the Srebrenica massacre in mid-1993, where he was

among more than 8,000 men and boys killed in the massacre.

The Bosnian War occurred in Bosnia and Herzegovina

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The sectarian conflict

Upon

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The purveyor of those atrocities were the Serbian Orthodox

Christians.

sect, to be sure, but, nevertheless, all of this suffering and

pain and war crimes visited upon Mr. Ramic by Orthodox

Christians.

receive punishment that they so freely dealt out to him, yes,

yes, he reveled in that.

explanation, and I think the Court should consider that.

Cops are also Orthodox Christians.

When he sees these other Orthodox Christians

Is that an excuse?

Thank you, Your Honor.

No, but it is an

Mr. Ramic may want to address the

Court.

THE COURT:

MR. WENDELSDORF:

A different

speak right into it.

Mr. Ramic.

Pull it right up close to you and

It's not very good.

THE DEFENDANT:

My counsel advised me not to, I guess,

give a statement being the fact that I might antagonize someone,

but I think that's coming from someone who the injustice has not

been done with.

my own truth when it comes to this whole issue; right?

So first of all, I want to say --

THE COURT:

(Simultaneous speaking not reportable.)

If you would, please, pull that microphone

to you a little bit more.

And for that fact, I think that I need to speak

MR. WENDELSDORF:

You've got to get right up in there

Speak right into it.

THE DEFENDANT:

So first of all, I want to say that

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I'm an innocent man.

completely reject them.

You know, I don't accept these charges.

And I know why I'm here.

I'm here to suffer in the name of

Allah.

said in the Turkish court after being found guilty by a jury of

his peers for providing material support, designated foreign

terrorist organization, PKK, except that he said he was

suffering in the name of Jesus, you know.

And these are the same exact words that Andrew Brunson

See, every single time U.S. citizens are locked up abroad,

they automatically get a [indiscernible] designation as

wrongfully detained.

Griner, Trevor Reed, Paul Whelan, everyone else.

didn't get that benefit of the doubt?

politically motivated, so is mine.

It's politically,

religiously, and racially as well.

Not just abroad but here in

the United States, you know.

You know, we saw that with Brittney

How come I

If their cases are

So I believe that this was a sham trial from -- I mean, sham

prosecution from the start.

that was brought by biased, prejudiced, I believe, and rogue and

corrupt prosecutors, you know, with a compromised grand jury

just abusing discretion.

the rest of the D.C. bureaucrats, you know, I think they're

upholding the same communist Marxist Islamophobes, you know,

upholding the manifesto of the PKK comrades.

You know, sham and -- prosecution

You know, Chris Tieke, Josh Judd, and

For example, I believe that this whole -- you know, this is

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a weaponized two-tiered system of justice with no equal

application of any laws, black or white.

that extraterritorial jurisdiction, dual sovereignty applies to

me but does not apply to thee, you know.

the rule of law, no respect for the treaties, no respect for

international law, and that is why they had to resort to

forcible kidnapping in order to bring me back here, you know.

And that was proven by the Ministry of Justice of another

country.

You know, they say

There's no respect for

You know, the prosecution claims that foreign countries on

standing of double jeopardy has no relevance to the Fifth

Amendment of the United States Constitution, but somehow the

same Constitution has relevance when it comes to an Anglo-Saxon

Christian for violating the same statutes as me.

are awarded with a visit to the White House, you know, a speech

in the Congress, and a meeting with Senator and Minority Leader

Mitch McConnell and are painted as, you know, patriots and --

heroes and patriots; right?

Individuals

I mean, this nation is coming up on 250th year since it was

founded, you know, and I believe it's been drafted or at least

in our time enforced to benefit only one set of people.

that the whole Supreme Court needs to revisit the selected

prosecution and its biased ruling; right?

I think

And what else?

You know, today I'm being sentenced for -- I'm not going to

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say allegedly violating 2339B.

But if that's the case, then the

whole Congress, the House and the Senate and everyone that voted

yea or abstained from a vote in support of PKK, needs to be

charged, including Donald Trump for, you know, doing the same by

saying -- by abusing his executive powers, you know.

myself, How does the United States ally itself with an ideology

that it's supposed to have been fighting since 1950s, you know,

the McCarthy era, and the same policies that were implemented by

Ronald Reagan that contributed to me coming to this country in

the first place?

I'm asking

And on the other side of the aisle, while I was in the

immigration center in Turkey 2021, I watched Joe Biden sign a

peace accord agreement in Sweden, Stockholm, recognizing the

Houthis -- taking the Houthis off the DTFO list, recognizing

them as a de facto government, and giving them economical and

political support.

and the demographic cleansing of Sunni populations in Yemen.

this not a violation of 2339B, you know?

And all of this led to the ethnic cleansing

Well, if you look at the statute of 2339B, there's an

exemption to it.

What is the exemption?

You can support, you

can engage in any forms of terrorism as long as you have the

stamp approval of the U.S. Attorney General.

say, according to this draconian law, that the United States is

the biggest sponsor of terrorism when it's in their interest to

do so.

Then one might

But for us, for other people, their best interests is

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preventing the genocide of their people, taking matters into

their own hands, and not wait on some UN Security Council or

United States inability to stand up to the Russia-China veto.

You know, this is a whole story that repeats itself -- we all

know it too well -- at the expense of us.

And before I conclude on the PSR and the trial, you know,

PKK, its founder has been incarcerated since 1998.

successor, cofounder, and his cousin was on an Interpol red

notice alert as an international fugitive, but somehow he's

allowed to come to this country, even meets with Senator Lindsey

Graham, and is openly soliciting funding for his organization.

You know, we didn't see the DOJ, we didn't see no grand juries

or any prosecutors taking action because they endorse these

groups, the same groups that they designate as FTOs.

His

Another DFTO that they're talking about in motions is the

YPG and the PYD.

alert and was arrested in Czech Republic, right, awaiting

extradition to multiple countries.

blessing of the DOJ, this person is released and allowed to

travel throughout Europe and the United States.

Its founder also was on an Interpol red notice

But, once again, with the

Another thing, in January, the United States just crafted a

$10 million bounty on an HDS leader and recognized it as a

de facto government, you know, and was in Damascus and

everything else.

power vacuum, for the sake of the profits and interest, the

So one might say, well, for the sake of the

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United States is -- the United States government is willing to

become a state sponsor of terrorism.

saying -- you know, the Confessions of an Economic Hit Man, a

former CIA agent said this decades ago; right?

And this is not me

And if you remember, last year during the campaign of Donald

Trump, he's telling the America people we are fighting radical

Marxist communists, but at the same time behind closed doors and

openly, he's aiding and abetting these Marxist communists,

including PKK.

turn around and use against a NATO member country

[indiscernible] Article 5 of his charter; right?

that doesn't matter when it comes to the Turkish regime, you

know.

They were given, you know, tons of weapons they

But I guess

But what I'm trying to -- what I'm trying to say is that

these people that are painting me as a, you know, danger and

threat, I think they pose more national security -- more

national security, you know, threat to this country than I ever

will.

You know -- let me see what else.

As far as the danger and the risk and threat to the society,

you know, I can name several cases -- I think this whole claim

is exaggerated by the prosecution.

individuals not only being released on bond, own recognizance,

but while being released picking up additional charges of

obstruction of justice.

I can name several cases of

Still, they're allowed to remain free,

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you know, and ultimately getting as low as 42 months.

And they're talking about me being a danger and risk and

threat to society.

Why bring me here in the first place?

Why

spend a million dollars of taxpayer dollars to bring me here on

the same plane?

convicted me without having counsel, without having a jury

trial, you know, they didn't see me as a danger or risk and

threat to society when they released me for a couple of months

before they put me in an immigration center.

exaggerated.

And the same Turkish regime that wrongfully

And all of this

Since 2015, 9 out of the 12 individuals similarly situated

as me -- more counts, more severe charges, you know, picked up

from the scene of the crime, brought from Syria -- are here in

the United States.

how come?

They served out their sentences or are on supervised

release.

You know, 9 out of those 12, I have served more time

in pretrial solitary confinement than their whole sentences.

And the remaining three individuals, you know, they're projected

to be released in 2027 and 2030.

I've been incarcerated for ten years.

most cruel, harsh, and unusual punishment in solitary

confinement.

They're in the United States society.

Well,

And I spent most -- right now,

I spent my time in the

And all of the cases that they're quoting in the sentencing

memorandum has no similarity whatsoever with this case because

all the cases are individuals who have -- don't have a normal

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2339B.

It's 2339B resulting in death.

And the other two cases

that are quoted are individuals who had 2339B but had other

counts that aggravated the charges, like United States vs.

Mumuni Saleh who had a 2339B with attempted murder on FBI

agents; or David Wright, a 2339B with assault on FBI agents that

resulted in the death of his uncle; right?

So how come they're not -- how come they're not quoting

cases I'm quoting if I'm such a danger, risk, and threat to

society?

brought over here, he's in the United States.

El Hassani, who the PBS -- PBS Frontline made a documentary

about, picked up from Syria, has ten more counts than me, and

ends up getting six years, only serves two and a half years.

Like Warren Clark that was picked up from Syria and

THE COURT:

All right.

interrupt you for a second.

THE DEFENDANT:

THE COURT:

Mr. Ramic, I'm going to

Can I just mention --

I need to take a break, okay?

I'll be

right back.

(Recess.)

THE COURT:

had to take a break.

Or Samantha

All right.

Mr. Ramic, I'm sorry, but I

So please continue.

THE DEFENDANT:

I just wanted to continue on the

danger, risk, and threat to the society.

to come to this country, nor do I wish to stay here.

chance, I'm definitely going to be leaving.

73a

My intention was never

So given a

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But if -- you know, this exaggerated claim that I'm --

supposedly, you know, to protect the society and threat, I

already mentioned how the Turkey government dealt with me when I

was released in their society.

I'm such a danger, risk, and threat to society, you know, the

FBI, you know, they have many cases of their own that they are

hiding and don't want everyone to know about.

But if I am so -- you know, if

Look, for example, United States vs. Daniella Green.

agent went to Syria, joined ISIS, married the ISIS leader, was

arrested, brought back to the United States, and guess what?

Receives a two-year prison term with three years' supervised

release, which has already been completed; right?

the last person to be shown leniency, slap on the wrist.

know, with the betrayal of the agency, with the knowledge,

training from the academy in Virginia, no, this person does not

pose a danger, risk to society.

D.C.

And this is

You

She's roaming the streets of

But when it comes to me, all of a sudden, oh, he's the most

dangerous.

worried about him, you know.

mentioned.

FBI

He's the walking Hiroshima/Nagasaki.

We have to be

And the other cases that I

Like I said, I've been -- ten years right now I've been

locked up.

All of the people that were in prison with me in

Turkey, regardless of their nationality, whether they were

serving out their sentences, they had gotten deported back to

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their countries, or had suspended sentences, all of those

individuals that were deported back to their countries, none of

them were successfully prosecuted for a second time.

only such case in the whole history of the United States when it

comes to 2339B.

I'm the

There has not been a case before.

So I'm asking why.

I think this is politically motivated.

I believe, you know, it was a puppet show.

[Indiscernible] I

don't even know.

credentials to their resumé, seeking a job promotion, or maybe

even use this as a future campaign propaganda tool to challenge

Mr. Greenberg's office in Louisville or something like that.

Maybe somebody wants to use this to add

And, you know, when we speak about this whole issue about,

you know, federal crime of terrorism, you know, is a crime that

is defined to influence or affect the conduct of government by

intimidation, coercion, or to retaliate against the conduct of

government, right now you have a world legion of U.S. citizens

and individuals from 180 countries violating the same

[indiscernible] in Ukraine and inside Russian Federation.

everybody's going back and forth.

because they're not Muslim and they're fighting a,

quote/unquote, criminal regime, including Trevor Reed, who,

after being released from prison, went back over there and got

injured; right?

And

Nobody's being charged

You know, the same issue happened in Southeast Europe.

Different Christian denominations were going -- on both sides of

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the conflict fighting, and nobody's being charged, nobody's

being arrested.

all of a sudden this didn't sit well with the European Union.

So they imposed their will on these other countries and proposed

a new bill, you know, making it punishable anyone going to join

paramilitary organizations abroad, whether it be Syria, Ukraine,

or anywhere else.

years.

As soon as the Muslims start going to Syria,

Make it punishable from one year to five

But up until now, not one non-Muslim has been charged with

this new law, but hundreds of people returning from Syria have

been, including the ones that joined the Free Syrian Army, the

opposition.

supporting in a proxy war.

these definitions, they have an overreach and, to my believing,

is just some kind of Ponzi scheme designed to target only one

set of people and target on the Muslims.

The same opposition that Barack Obama was

And let's be honest.

So, once again, we see that some of

There's a famous story where Donald

Trump always brings up about, you know, his meeting with the

Chinese leader Xi Jinping where he tells him -- I guess through

an interpreter where he tells him or try to intimidate him by

telling him, "Look, I just struck the Syrian government with 150

Tomahawk cruise missiles."

Is this not a federal crime of terrorism?

Is this not

intimidation, coercion, or trying to, you know, retaliate

against the conduct of a government?

76a

And was this government

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illegitimate?

and the counsel's point.

standing next to me to get charged as well.

say that's another presidential immunity, just like the January

6th insurrection?

If you say yes, then that just proves my point

If you say no, then he needs to be

Or you're going to

You know, where's my immunity in all of this?

successive, selective, vindictive prosecution?

politically motivated prosecution?

From

Immunity from

You know, a Florida judge dismisses and throws out a case

because she believes it's politically motivated.

judge grants motions, dismisses counts because the person

happens to be the son of a president, you know.

this plutocracy, you know, favoritism is no different than the

rest of the oligarchs and aristocrats that are around the world.

It's basically a flawed system, while all the while targeting

minorities like myself now for the second and third time and

possibly if I get out early maybe for the fourth time.

A California

And, you know,

You know, at the end of the day, I believe that any sentence

imposed upon me today will be a continuation of injustice.

that being said, you know -- with that being said, I believe if

the Court has an atom's weight of justice, I think you should do

the right thing, and I believe the right thing is an

unconditional discharge, my immediate release, even an apology

and compensation for being wrongfully detained for the past

three and a half years and held as some kind of, you know,

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scapegoat or political hostage.

If anything else, I don't need to worry about the

8 U.S.C. 1452 or 424 being stripped.

back to the European continent, what you call is my native land.

MR. WENDELSDORF:

Thank you, Your Honor.

THE COURT:

Just deport me.

Deport me

Thank you, Mr. Ramic.

All right.

Well, start in this case, as

in all cases, with the United States Sentencing Commission

guidelines, which suggest, based upon an offense level of 40 and

a criminal history category of VI, a sentence of between 360 and

600 months' imprisonment, but from there I'm instructed by

18 U.S.C. 3553(a) to impose a sentence that is sufficient, but

not greater than necessary, to punish the crime in this case, to

deter other U.S. citizens from joining with foreign terrorist

organizations, to promote respect for the law, to protect the

public, importantly to avoid unwarranted disparities among

similar defendants.

account the history and characteristics of the defendant and the

nature and circumstances of the crime.

And in doing so, I need to take into

As Mr. Wendelsdorf pointed out and the PSR does too,

Mr. Ramic was born into a society that was torn by civil war and

sectarian violence.

witnessed his father's murder, other atrocities .

the U.S., then to Bowling Green with as many as 6,000 other

Bosnians.

He, I think, according to the PSR,

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He came to

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And I still remember that influx.

It had a vast influence

on our community.

this day, the Bosnian refugees that came to the United States,

especially to Bowling Green, have become woven into the fabric

of our country and have made immense contributions to this area.

Almost all for the positive.

But not Mr. Ramic.

You know, to

He -- and I'm not being critical of him.

He had an unpleasant acclimation to the United States.

First in

Kansas, then here in Bowling Green.

unhappy.

early 20s, by the extremist views of radical Sunni Muslim

clerics, and he developed a sincere -- what I think the evidence

has been clear was a sincerely held belief that he had an

obligation to go to war for his religion.

different if he had actually hooked up with Al-Qaeda in 2010.

There's no question that's why he went to -- or tried to go to

Saudi Arabia and Yemen.

He was disillusioned,

He was influenced at an impressionable age, in his

Things might be

And, frankly, it's just my impression that Al-Qaeda was

engaged in more acts of random violence that I do think of as

terrorism as opposed to the legal definition that we're dealing

with in this case.

unsuspecting civilians.

Again, the random acts of violence against

So -- which led to his then in 2014 successfully making his

way to Syria to join ISIS.

And I do think to me this case is as important about what

it's not as opposed to what it is.

79a

There is no evidence that

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Mr. Ramic undertook to engage in any acts of terrorism as -- in

a more common sense term of that.

violence directed at innocent populations intended to sew terror

among general population.

horrible incidents of gun violence against crowds.

what he did was he went to join an army, and that's what he did.

To me, probably the most significant piece of evidence in

terms of what Mr. Ramic actually did was the form that ISIS had

when he -- when Ramic enlisted, and it lists all of the kinds of

information that a standard army would be expected to have for

its soldiers, including, you know, a box to check as to whether

he wanted to be a fighter or a martyr or a suicide bomber.

he wanted to be a fighter.

the evidence was clear that he wanted to fight for a caliphate

where the Sunni Muslims would require strict adherence to sharia

law.

Again, random acts of

There were no bombs.

There were no

There was --

He wanted to fight a war.

But

I think

And I think to most Christians, most Americans, maybe most

Muslims, that is an extreme version of their religion.

Nevertheless, that's what he believed, and that's what he went

to help create.

He fought as a soldier.

had engaged in any acts of senseless violence against innocent

people, I think this case would be completely different.

He joined as a soldier, and that's what he did.

If there was evidence that Mr. Ramic

So in terms of punishing his actions, there's no question

that he violated these three charges, these three counts of the

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indictment, and that we need to deter American citizens from

going to work with foreign terrorist organizations.

But one of the big factors, ultimately, that I see is

avoiding unwarranted disparities among similar defendants, and

in that regard, we've got statistical data from other defendants

who have been convicted of similar-based crimes, of the same

base crime, and have the identical criminal history and offense

level as Mr. Ramic.

sentenced to 220 months in prison.

imposed of 168 months.

texture to what these other defendants did, these other folks

who have been convicted of the same crime.

The average of those defendants have been

A median sentence has been

And I frankly don't have a whole lot of

Frankly, given the nature of the participation in an

organized army intent on capturing a piece of territory for the

creation of their own state, I tend to view this more along the

median of 168 months.

seems to be no question in my mind that Mr. Ramic deserves

credit for the 67 months he served in a Turkish prison, which

then results in a sentence of 101 months.

Against that period of 168 months, there

And it is therefore the judgment of the Court that Mr. Ramic

will be committed to the custody of Bureau of Prisons for a term

of 101 months as to Counts 1 and 2, which shall be served

concurrently, for a term of 101 months.

of the indictment, because I think otherwise if I sentence him

to any time in prison on that one, I don't think I could credit

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With regard to Count 3

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him with the time served or at least I'm concerned I can't, I'm

going to impose a fine on Count 3 of $25,000.

And upon release from imprisonment, he'll be placed upon

supervision or supervised release for a term of life as to each

of Counts 1, 2, and 3, which shall be served concurrently, for a

term of life.

to abide by the standard conditions of supervision adopted by

the Court as well as the special conditions that were outlined

in Subpart G of the presentence report.

include that, if deported, Mr. Ramic may not re-enter the United

States without written permission of the Secretary of Homeland

Security, participation in mental health treatment, a number of

computer- and technology-based restrictions, and a search and

seizure condition.

While on supervision, Mr. Ramic will be required

Those conditions

Mr. Ramic will be required to pay a special penalty

assessment fee of $100 as to each count of conviction, for a

total of $300.

Restitution is not an issue in this case.

The cost of

investigation, prosecution, incarceration, and supervision will

be waived due to the defendant's inability to pay.

course, the $25,000 fine will be imposed.

But, of

Having considered 18 U.S.C. 3553(a) and the advisory

guidelines, which produce a total offense level of 40 and a

criminal history category of VI, the advisory guideline ranges

are 360 months' to 600 months' imprisonment, a fine of 50,000 to

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250,000 dollars, and 1 to 3 years of supervision.

reasons that I have given, I do believe that a sentence of 101

months' custody for Counts 1 and 2, a fine of $25,000 as to

Count 3, I believe, is sufficient, but not greater than

necessary, to comply with the purposes set forth in the statute.

Mr. Wendelsdorf, are there any objections to the sentence

pronounced or conditions imposed which have not previously been

raised?

MR. WENDELSDORF:

THE COURT:

All right.

No, Your Honor.

Based on the

Thank you.

All right.

Mr. Ramic, you've got the right to appeal your

case to the Sixth Circuit Court of Appeals, which on proper

appeal will review the case and determine whether there's been

an error of law.

the appeal, you have the right to apply for leave to appeal in

forma pauperis, which means you may appeal without having to pay

for it.

desire to appeal and so request, the Clerk of this Court will

prepare a notice of appeal on your behalf.

must be filed within 14 days from the entry of judgment.

If you don't have sufficient money to pay for

If you're without the services of an attorney and

A notice of appeal

If you don't have sufficient funds to employ an attorney,

the Court of Appeals may appoint your present attorney or

another attorney to prosecute the appeal for you.

You may also request to be released on reasonable bond

pending the appeal.

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We've got a form for you to sign acknowledging that I

advised you of these rights.

Mr. Wendelsdorf, anything further?

MR. WENDELSDORF:

No, sir.

THE COURT:

All right.

MR. JUDD:

Yeah.

Thank you, Judge.

Mr. Judd, anything further?

Just for the record, Judge,

because -- for appeal purposes, the United States would have to

object to the sentence.

THE COURT:

Very well.

MR. JUDD:

Thank you.

THE COURT:

All right.

(End of proceedings.)

We're adjourned.

C E R T I F I C A T E

I am an official court reporter for the U.S. District Court

for the Western District of Kentucky and certify that the

foregoing is a true and correct transcript, to the best of my

ability, of the above pages, of the digital audio recording

provided to me by the Court of the proceedings taken on the date

and time previously stated in the above matter.

s/Terri L. Horton

Terri L. Horton, RMR, CRR

Official Court Reporter

84a

April 22, 2025

Date

I. U.S.S.G. § 3A1.4. Terrorism

(a)

If the offense is a felony that involved, or was intended to promote, a

federal crime of terrorism, increase by 12 levels; but if the resulting

offense level is less than level 32, increase to level 32.

(b)

In each such case, the defendant's criminal history category from

Chapter Four (Criminal History and Criminal Livelihood) shall be

Category VI.

Commentary

Application Notes:

“Federal Crime of Terrorism” Defined.—For purposes of this guideline,

“federal crime of terrorism” has the meaning given that term in 18 U.S.C. §

2332b(g)(5).

Harboring, Concealing, and Obstruction Offenses.—For purposes of this

guideline, an offense that involved (A) harboring or concealing a terrorist who

committed a federal crime of terrorism (such as an offense under 18 U.S.C. §

2339 or § 2339A); or (B) obstructing an investigation of a federal crime of

terrorism, shall be considered to have involved, or to have been intended to

promote, that federal crime of terrorism.

Computation of Criminal History Category.—Under subsection (b), if the

defendant's criminal history category as determined under Chapter Four

(Criminal History and Criminal Livelihood) is less than Category VI, it shall

be increased to Category VI.

U.S.S.G. § 3A1.4 (bold removed).

85a

Appendix E

II. 18 U.S.C. § 11. Foreign government defined

The term “foreign government”, as used in this title except in sections

112, 878, 970, 1116, and 1201, includes any government, faction, or body of

insurgents within a country with which the United States is at peace,

irrespective of recognition by the United States.

18 U.S.C. § 11.

III. 18 U.S.C. § 1116. Murder or manslaughter of foreign officials,

official guests, or internationally protected persons

(b) For the purposes of this section:

(2) “Foreign government” means the government of a foreign country,

irrespective of recognition by the United States.

18 U.S.C. § 1116(b)(2) (bold removed).

IV. 18 U.S.C. § 2332b. Acts of terrorism transcending national boundaries

(g) Definitions.--As used in this section-(5) the term “Federal crime of terrorism” means an offense that—

(A) is calculated to influence or affect the conduct of government

by intimidation or coercion, or to retaliate against government conduct;

and

(B) is a violation of-(i) section 32 (relating to destruction of aircraft or aircraft

facilities), 37 (relating to violence at international airports), 81

(relating to arson within special maritime and territorial

jurisdiction), 175 or 175b (relating to biological weapons), 175c

(relating to variola virus), 229 (relating to chemical weapons),

subsection (a), (b), (c), or (d) of section 351 (relating to

congressional, cabinet, and Supreme Court assassination and

kidnaping), 831 (relating to nuclear materials), 832 (relating to

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participation in nuclear and weapons of mass destruction threats

to the United States)1 842(m) or (n) (relating to plastic

explosives), 844(f)(2) or (3) (relating to arson and bombing of

Government property risking or causing death), 844(i) (relating

to arson and bombing of property used in interstate commerce),

930(c) (relating to killing or attempted killing during an attack

on a Federal facility with a dangerous weapon), 956(a)(1)

(relating to conspiracy to murder, kidnap, or maim persons

abroad), 1030(a)(1) (relating to protection of computers),

1030(a)(5)(A) resulting in damage as defined in

1030(c)(4)(A)(i)(II) through (VI) (relating to protection of

computers), 1114 (relating to killing or attempted killing of

officers and employees of the United States), 1116 (relating to

murder or manslaughter of foreign officials, official guests, or

internationally protected persons), 1203 (relating to hostage

taking), 1361 (relating to government property or contracts),

1362 (relating to destruction of communication lines, stations, or

systems), 1363 (relating to injury to buildings or property within

special maritime and territorial jurisdiction of the United States),

1366(a) (relating to destruction of an energy facility), 1751(a),

(b), (c), or (d) (relating to Presidential and Presidential staff

assassination and kidnaping), 1992 (relating to terrorist attacks

and other acts of violence against railroad carriers and against

mass transportation systems on land, on water, or through the

air), 2155 (relating to destruction of national defense materials,

premises, or utilities), 2156 (relating to national defense material,

premises, or utilities), 2280 (relating to violence against

maritime navigation), 2280a (relating to maritime safety), 2281

through 2281a (relating to violence against maritime fixed

platforms), 2332 (relating to certain homicides and other

violence against United States nationals occurring outside of the

United States), 2332a (relating to use of weapons of mass

destruction), 2332b (relating to acts of terrorism transcending

national boundaries), 2332f (relating to bombing of public places

and facilities), 2332g (relating to missile systems designed to

destroy aircraft), 2332h (relating to radiological dispersal

devices), 2332i (relating to acts of nuclear terrorism), 2339

(relating to harboring terrorists), 2339A (relating to providing

material support to terrorists), 2339B (relating to providing

material support to terrorist organizations), 2339C (relating to

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financing of terrorism), 2339D (relating to military-type training

from a foreign terrorist organization), or 2340A (relating to

torture) of this title;

(ii) sections 92 (relating to prohibitions governing atomic

weapons) or 236 (relating to sabotage of nuclear facilities or fuel)

of the Atomic Energy Act of 1954 (42 U.S.C. 2122 or 2284);

(iii) section 46502 (relating to aircraft piracy), the second

sentence of section 46504 (relating to assault on a flight crew

with a dangerous weapon), section 46505(b)(3) or (c) (relating to

explosive or incendiary devices, or endangerment of human life

by means of weapons, on aircraft), section 46506 if homicide or

attempted homicide is involved (relating to application of certain

criminal laws to acts on aircraft), or section 60123(b) (relating to

destruction of interstate gas or hazardous liquid pipeline facility)

of title 49; or

(iv) section 1010A of the Controlled Substances Import

and Export Act (relating to narco-terrorism).

18 U.S.C. § 2332b(G)(5) (bold removed).

V. 18 U.S.C. § 2332f. Bombings of places of public use, government facilities,

public transportation systems and infrastructure facilities

(e) Definitions.--As used in this section, the term—

(12) “state” has the same meaning as that term has under international

law, and includes all political subdivisions thereof.

18 U.S.C. § 2332f(e)(12) (bold removed).

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.