Robin Kuntz, a current CLR member, analyzes the implications of the Ninth Circuit's decision in United States v. Ressam, the first case in the jurisdiction involving the criminal sentencing of a terrorist under the advisory Sentencing Guidelines. Kuntz concludes that although the Guidelines do not offer a clear standard by which a court must set a criminal defendant's punishment, this is advantageous, particularly in cases involving terrorists like the "Millennium Bomber," the defendant at the heart of Ressam.

This case note is one of seven written by California Law Review members for Circuit's first case note program.