Ninth Circuit Orders New Trial for Arizona Man Over ISIS Support Conviction
Ninth Circuit finds insufficient evidence to uphold Abdul Kareem's ISIS support conviction.
Why it matters: This ruling clarifies evidentiary standards required to prove conspiracy in terrorism support cases, guiding defense and prosecutors.
- Ninth Circuit reversed Abdul Malik Abdul Kareem's 2016 conviction on conspiracy to provide material support to ISIS on November 6, 2026.
- Court ruled insufficient proof that Kareem intended to join ISIS conspiracy; actions deemed independently inspired by ISIS ideology.
- Other convictions, including firearms charges and false statements to FBI, were affirmed by the court.
- Judge Daniel P. Collins dissented on the conspiracy count, arguing evidence supported Kareem’s conviction.
On November 6, 2026, the Ninth Circuit Court of Appeals reversed Abdul Malik Abdul Kareem's conviction on Count 5 for conspiracy to provide material support to ISIS under 18 U.S.C. § 2339B(a)(1). The court concluded the government failed to prove Kareem intended to join a conspiracy directed or coordinated by ISIS when he supplied weapons to terrorists involved in a 2015 attack.
Judge Salvador Mendoza Jr. noted, "At most, the evidence demonstrated that Kareem was independently inspired by ISIS's ideology and goals," emphasizing that the government needed stronger evidence to sustain the conviction. The panel directed the district court to enter a judgment of acquittal on this count and resentence Kareem accordingly.
Despite this reversal, the Ninth Circuit upheld Kareem's other convictions, including transporting firearms across state lines, making false statements to the FBI, and illegal possession of a firearm. These charges notably carried heavy penalties separate from the terrorism support conviction.
Judge Daniel P. Collins dissented in part, contending that Kareem’s actions could be interpreted as providing support to ISIS, and that the evidence was sufficient to uphold the conspiracy conviction. He criticized the majority’s narrow reading of § 2339B as inconsistent with the defense position Kareem had taken during trial.
Kareem was initially sentenced to 30 years in prison following his 2016 conviction related to his involvement in support of attackers during a 2015 shooting at a Muhammad Art Exhibit and Contest in Garland, Texas. This case highlights the ongoing legal challenges in terrorism prosecutions, particularly the evidentiary threshold for proving an individual’s intent and agreement to join terrorist conspiracies under U.S. law.
By the numbers:
- 2026-11-06 — Date of Ninth Circuit decision reversing terrorism support conviction
- 2016 — Year of Abdul Kareem's original conviction
- 30 years — Original sentence for Abdul Kareem including all counts
Yes, but: While the majority found insufficient evidence for conspiracy, other significant convictions against Kareem were affirmed, maintaining substantial penalty exposure.
What's next: The district court will resentence Kareem on the affirmed counts and enter acquittal on the reversed conspiracy charge; government appeal status is currently unknown.