Medunjanin v. United States, 99 F.4th 129

Adis Medunjanin was convicted in 2012 on several terrorism-related counts, including two under 18 U.S.C. § 924(c) for possessing a destructive device in furtherance of a crime of violence.
One § 924(c) count was predicated on attempted terrorism; the other on conspiracy to commit murder abroad and receiving military-style training from a foreign terrorist organization.
Following Sessions v. Dimaya and United States v. Davis, Medunjanin moved to vacate his § 924(c) convictions, arguing the predicates were not valid crimes of violence.
The district court agreed to vacate the § 924(c) count based on conspiracy to commit murder and training but upheld the one based on attempted terrorism, deeming it categorically a crime of violence.
Medunjanin appealed, focusing on whether his liability for the attempted terrorism predicate (and thus his § 924(c) conviction) could stand if the jury had convicted him on an aiding and abetting theory.
The Second Circuit granted a certificate of appealability on this narrow aiding and abetting question and affirmed the district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does conviction for aiding and abetting a crime of violence invalidate a § 924(c) predicate?	Medunjanin: Aiding and abetting liability should not supply a valid predicate if the defendant didn’t personally use force.	Government: Aiding and abetting is equivalent to principal liability for a crime of violence.	Conviction for aiding and abetting a crime of violence is itself a valid basis for a § 924(c) predicate.

Sessions v. Dimaya, 584 U.S. 148 (declared the residual clause in 18 U.S.C. § 16(b) unconstitutionally vague)
United States v. Davis, 139 S. Ct. 2319 (extended Dimaya to § 924(c), striking the residual clause)
United States v. Taylor, 596 U.S. 845 (held attempted Hobbs Act robbery is not categorically a crime of violence)
Gonzales v. Duenas-Alvarez, 549 U.S. 183 (confirmed aiders and abettors are treated like principals in criminal liability)