Following a jury trial, Defendant Hadi Matar was convicted of each charge contained in a three-count indictment.
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Matar → follow → indictment
Count 1 charged Matar with attempting to provide material support to a designated foreign terrorist organization ("FTO")—that is, Hizballah, in violation of 18 U.S.C. § 2339B(a)(1).
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Count → charge → §
Count 2 charged Matar with committing an act of terrorism transcending national boundaries, in violation of 18 U.S.C. § 2332b(a)(1)(A).
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Count → charge → §
Count 3 charged Matar with providing material support to terrorists, in violation of 18 U.S.C. § 2339A.
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Count → charge → §
The charges against Matar stemmed from his stabbing of the author Salman Rushdie … at the Chautauqua Institution on August 12, 2022 ….
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charges → stem → August
Matar moved for a judgment of acquittal, but the court said no.
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court → move → acquittal
Here's an excerpt from the discussion of why Matar was acting sufficiently under the direction of a foreign terrorist organization (which is required under the relevant federal statute) rather than just independently—if he had been acting independently, that would have still been attempted murder punishable under state law, but likely not a violation of these statutes:
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that → act → statutes
As charged in Count 1, [18 U.S.C. § 2339B] criminalizes attempting to provide "material support or resources," including "personnel" and "services," to a designated foreign terrorist organization.
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§ → charge → organization
Matar asserts that Count 1 should be "set aside because the Government did not prove that Defendant provided material support to Hizballah under the controlling rule announced in United States v. Ullah [2d Cir. 2026]."
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Defendant → assert → Ullah
According to Matar, the "controlling issue" is "whether the alleged 'personnel' and 'services' were legally provided to Hizballah at all.
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personnel → accord → Hizballah
Specifically, seizing upon the Second Circuit's recent decision in Ullah, Matar maintains that while he, much like Ullah, was inspired by, was ideologically aligned with, and was intent on benefitting an FTO, such evidence was "not enough" to establish that he was acting under the direction and control of (as required under the "personnel prong")—or acting in coordination with or at the direction of (as required under the "services prong")—such FTO….
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he → seize → FTO
Considering all the evidence presented at trial, a properly-instructed jury found beyond a reasonable doubt that Matar attempted to provide himself, as "personnel," and his conduct, as a "service," to Hizballah….
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Matar → consider → Hizballah
[T]he jury, considering the evidence presented at trial, reasonably determined such evidence to be sufficient to establish: (1) that Matar, in repeatedly stabbing and attempting to murder Rushdie, provided personnel and services to Hizballah; and (2) that at the time he committed such acts, Matar was acting at the direction Hizballah, by attempting to fulfill the fatwa—which was originally issued by the Supreme Leader of Iran, Ayatollah Khomeini, and was subsequently endorsed, in 2006, by Hassan Nasrallah, then-Secretary General of Hizballah, and again, in 2017, by the Ayatollah Khomeini's successor, Ayatollah Khamenei—calling for Rushdie's murder.
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which → consider → murder
This Court sees no reason to disturb that conclusion.
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Court → see → conclusion
{At trial, the Government introduced expert testimony from Dr. Matthew Levitt, which established, [among other things], that Hizballah functions as a proxy organization for the Iranian government.
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Hizballah → introduce → government
Levitt further testified that Nasrallah's 2006 speech endorsing the Ayatollah Khomeini's fatwa involving Rushdie, which was broadcast over Al Manar, Hizballah's satellite television network, was a "call to action."
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which → testify → action
As described previously, Matar included the videotape broadcast of Nasrallah's 2006 speech in a couple of videos that he produced prior to attacking Rushdie.}
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he → describe → Rushdie
To prove that Matar attempted to provide material support to a foreign terrorist organization by providing himself as "personnel," the Government must prove that Matar "attempted … to work under [the] foreign terrorist organization's direction or control or to organize, manage, supervise, or otherwise direct the operation of that organization."
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Matar → prove → organization
Put differently, "[i]ndividuals who act entirely independently of the foreign terrorist organization to advance its goals or objectives shall not be considered to be working under the foreign terrorist organization's direction and control."
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who → Put → direction
The Government's trial evidence reasonably established that in attacking Rushdie as he did, Matar was attempting to execute a very specific directive issued by the Ayatollah Khomeini and endorsed by Hizballah.
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Matar → establish → Hizballah
Unlike the ISIS video watched by Ullah which "urged supporters to commit attacks against America," Defendant endeavored to do precisely that which was commanded by the [Khomeini] fatwa [against Rushdie] and sought to kill a specific individual for a specific reason.
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which → watch → reason
Cf. Ullah ("The videos that [Ullah] watched that were issued by ISIS did not 'order' or 'command' him to do anything under any common understanding of those terms.
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that → watch → terms
Nor did they provide 'guidance or supervision of action, conduct, or operation'—since they were silent on specifics.").
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they → provide → specifics
Indeed, to the extent that Matar himself created what may fairly be characterized as promotional videos which included Hizballah Secretary General Nasrallah's endorsement and affirmation of the very specific fatwa calling for Rushdie's death, a reasonable jury could find that Matar's subsequent actions in stabbing and attempting to kill Rushdie were undertaken at Nasrallah's direction and command and Matar's conduct represented his effort to fulfill such directive, command, and order.
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conduct → create → directive
The Court in Ullah also explained that to work "under" an FTO's "direction" means that the FTO's "direction" or "control" must cause a defendant to "'suffer[ ] restriction, constraint, or control.'"
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defendant → explain → restriction
Here, the jury could reasonably have found that the existence of Hizballah's fatwa against Rushdie was the only reason Matar did what he did.
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he → find → what
Indeed, at trial, the government introduced evidence that Matar rejected a suggestion put forth to him by Kaymar in Iran [someone with whom Matar had been chatting online -EV] that consideration be given to killing another prominent American, because "Rushdie has fatwa longer" and "[The other prominent individual] doesn't have fatwa."
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individual → introduce → fatwa
In other words, the jury could reasonably have found that Matar's behavior was, in fact, dictated, directed and controlled exclusively by the existence of the FTO-endorsed fatwa.
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behavior → find → fatwa
Matar's own words and actions suggest that the only reason he did what he did was because he was attempting to do what he believed the Nasrallah-endorsed fatwa directed and commanded him to do it.
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fatwa → suggest → it
Furthermore, a rational jury could also have found that Nasrallah's speech provided "direction" because it ended by endorsing the concept of martyrdom.
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it → find → martyrdom
Dr. Levitt explained that martyrdom is a central part of Hizballah's ability to recruit and retain its followers.
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martyrdom → explain → followers
And the jury was presented with overwhelming evidence establishing Matar's expectation that in fulfilling the fatwa he would become a Hizballah martyr.
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he → present → fatwa
In that regard, the evidence at trial established that: (1) Matar, at the time he committed the attack, possessed a fake driver's license that contained references to several Hizballah martyrs, including Imad Mughniyah, who led Hizballah's terrorist arm for many years; (2) Matar, on the morning of the attack in August, visited a website run by Hizballah and took screenshots of two martyrs who had died in the month of August; (3) Matar had a lockscreen on his phone which depicted another Hizballah martyr, Samir Kuntar; (4) Matar had a photo of Ahmed Kassir—Hizballah's first martyr—on his bedroom wall; and (5) Matar sent his will to the Imam of his religious center several weeks before the attack, and he sent his will to another Imam two days before the attack.
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he → establish → attack
For all of these reasons, this Court concludes that the evidence presented by the Government at trial was sufficient to allow a rational jury to find that Nasrallah's 2006 speech guided or directed Hizballah's supporters to carry out Ayatollah Khomeini's fatwa on Rushdie, and that Matar, in attempting to carry out that fatwa on Hizballah's behalf, was doing so "under" Hizballah's "direction."
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Matar → conclude → direction
"'[R]estrict[ed], constrain[ed], or control[ed],'" by the fatwa, Matar targeted Rushdie alone.
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Matar → constrain[e → Rushdie
The fatwa and directive Matar received, and he was acting in furtherance of, was not a "hortatory, open-ended message."
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he → receive → furtherance
Unlike the ISIS video the defendant watched in Ullah—which merely "urged" supporters to commit unspecified attacks against the fatwa endorsed by Nasrallah that Matar attempted to fulfill directed that a specific person be killed for a specific reason.
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person → watch → reason
Such directive "constrain[ed]" Matar in the precise manner required under Ullah….
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directive → constrain[e → Ullah
The Court rejects Matar's suggestion that the evidence was insufficient because the government failed to present any evidence: that Hizballah knew of Matar or his plan before the attack; that Hizballah communicated with Matar about the attack (or that the people with whom Matar did communicate were, in fact, members of Hizballah); that Matar reported to or sought approval from Hizballah; or that Hizballah exercised any constraint over whether, where, or how Matar acted.
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Matar → reject → constraint
The law does not require such proof.
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law → require → proof
…and 5 more, not listed.
The Aporia
