U.S. Court of Appeals for the Second Circuit

United States v. Manaf

August 27, 2026

Summary

The court held that the omission of the jurisdictional predicate from the jury instructions on the statutory terrorism-related drug offenses was error, but did not warrant relief because the record established jurisdiction and there was no reasonable probability of a different outcome. It affirmed the conviction on Count Two, vacated the conviction on Count Three for insufficient evidence of the required intent, and rejected the challenges to expert testimony and prosecutorial summation. The judgment was therefore affirmed in part, vacated in part, and remanded for further proceedings.