United States v. Bekir Buluc

STUART KYLE DUNCAN, Circuit Judge:

A jury convicted Turkish national Bekir Buluc under 8 U.S.C. § 1253 (a)(1)(C) for "tak[ing] ... action" that was "designed to prevent or hamper" his removal from the United States. While immigration officers were escorting Buluc onto a commercial flight to Turkey, Buluc announced he would not board the plane and vigorously resisted the officers' attempts to carry him aboard. Airline personnel, witnessing the fracas, barred Buluc's boarding. At trial, Buluc claimed that the subsection under which he was prosecuted requires "joint" action. Invoking the canons…