Background
Mirsad Ramic, a naturalized U.S. citizen, traveled to Syria to join the Islamic State of Iraq and Syria. He received military training and fought in the siege of Kobane, an attack that resulted in over one hundred thousand deaths. Ramic was convicted of providing material support to a foreign terrorist organization and receiving military-type training. The district court sentenced him to one hundred one months, a variance of seventy-two percent below the advisory Guidelines range of three hundred sixty to six hundred months.
The court’s reasoning
The Sixth Circuit held that the terrorism enhancement applied because the term government includes the Assad regime under its ordinary meaning, regardless of U.S. recognition. The court further found that Ramic’s conduct was calculated to influence the United States. Regarding the sentence length, the court ruled it was substantively unreasonable because the district court minimized the seriousness of ISIS’s atrocities, ignored the need to protect the public from a dangerous recidivist, and improperly elevated national sentencing statistics over the Guidelines.
Because the district court’s substantial variance is substantively unreasonable, we vacate his sentence and remand for resentencing.
United States v. Ramic, 26a0144p.06 (6th Cir. 2026)
What it means going forward
Defendants convicted of providing material support to terrorist groups will face stricter scrutiny of below-Guidelines sentences. Courts must explicitly weigh the brutality of the organization and the risk of future danger rather than relying on median national statistics or narrow definitions of terrorism.