Earlier this month, 18-year-old Mahin Khan of Tucson, Arizona pleaded guilty to terrorism, conspiracy to commit terrorism, and conspiracy to commit misconduct involving weapons. The plea is unusual because it was entered in state court rather than federal court, making it Arizona’s first terrorism-related case.

State terrorism prosecutions are extremely rare, despite the fact that at least 33 states passed sweeping anti-terrorism legislation in the wake of 9/11. In the intervening fifteen years there have been over 400 federal terrorism prosecutions, but only a handful of state terrorism charges. (See examples of state prosecutions here, here, and here).