This Note analyzes the facts of the Ressam case and the legal analysis applied to it by both the Ninth Circuit and the Supreme Court. Part II discusses the intriguing history of the Ressam case. Part III examines the Ninth Circuit's reasoning in Ressam and shows why the Supreme Court was correct in reversing the improperly decided case. Part IV discusses the possible scope of the explosives statute under each interpretation--without or with a relational element. Finally, Part V concludes by commenting on the future of the explosives statute in light of the Supreme Court's decision, as well as the future of Ahmed Ressam.
Peter A. Talevich, During and In Relation To: How the Ninth Circuit Rewrote a Statute in the Case of the Millennium Bomber, 32 SEATTLE U. L. REV. 477 (2008).