United States v. Stewart

Attorney Lynne Stewart represented Abdel Rahman, a convicted terrorist leader subject to Special Administrative Measures (SAMs) limiting his mail, media, phone, and visitor access in prison. To access Rahman, Stewart signed affirmations agreeing to the SAMs, including a promise not to relay messages to or from third parties and to let interpreters discuss only legal matters. Over 14 months, however, Stewart distracted guards so Rahman and his interpreter could secretly discuss terrorist-organization business, and helped the interpreter pass messages to and from third parties, including a suspected terrorist leader. She also told a reporter that Rahman had withdrawn support for a cease-fire, which prompted the group to plan a new attack. A jury convicted Stewart of conspiring to defraud the United States, providing material support to terrorism, and making false statements; the trial court sentenced her to 28 months without resolving whether she had committed perjury or obstruction. Stewart appealed, arguing she should have been allowed to challenge the SAMs' validity or their applicability to her as an attorney.