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United States v. Ressam,
No. 07-455 (U.S., May 19, 2008): Carrying an Explosive: Ressam gave false information on his customs report while attempting to enter the United States. His car was searched and explosives were found (he intended to detonate them in this country). He was convicted of, inter alia, Making a False Statement to a Customs Official and Carrying an Explosive During the Commission of a Felony. The Ninth Circuit reversed the second conviction on the basis that the explosives must have been carried "in relation to" the underlying felony. HELD: REVERSED. Since Ressam was carrying explosives when he violated the statute proscribing the false statements, he was carrying them "during" the commission of that felony.
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