The Volokh Conspiracy
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Second Amendment Roundup: Group Self-Defense Against Terrorism
ROTC cadets kill terrorist in shooting at Old Dominion University.
On March 12, 2026, Mohamed Bailor Jalloh walked into a classroom at Old Dominion University in Norfolk, Virginia. He asked twice if it was a ROTC (Reserve Officers' Training Corps) class. When told that was, he shouted "Allahu Akbar" (God is Greater) and shot the instructor, Lt. Col. Brandon Shah, several times, killing him. He also shot and wounded two ROTC cadets. He used a Glock 44 .22 caliber rimfire pistol.
In an instant, "Hero ROTC cadet fatally stabbed ISIS-supporting Old Dominion gunman to prevent more carnage," reported the New York Post. Other cadets jumped on too, killing Jalloh. None of the cadets have been identified, which helps protect them from terrorist revenge.
Yet no official source has been cited for the fact that a cadet stabbed Jalloh, and nothing about the knife has been described.
At a news conference the same day, Dominique Evans, special agent in charge of the FBI Norfolk Field Office, stated "I'd like to acknowledge the students, who showed extreme bravery, by constraining the shooter and stopping further loss of life." When asked for more details, she continued, "There were students that were in that room who subdued him and rendered him no longer alive. I don't know how else to say it. But they were basically able to terminate the threat. He was not shot." No detail was added as to how they "rendered him no longer alive."
Jalloh was a naturalized U.S. citizen born in Sierra Leone. Jalloh had been a member of the Virginia Army National Guard, but was persuaded not to reenlist after hearing online lectures by Anwar al-Awlaki, a deceased Al-Qaeda leader. He lived in Nigeria during 2015-16, when he met with Islamic State members and became further radicalized. Back in the U.S. in 2016, he disclosed to an FBI confidential informant his plan to commit a mass shooting similar to the 2009 Fort Hood massacre, which left 13 dead. On July 2, 2016, Jalloh bought a rifle from a gun shop in northern Virginia. The gun shop was obviously cooperating with the FBI, as it secretly rendered the rifle inoperable before transferring it to Jalloh. The FBI arrested him the next day.
Pleading guilty to attempting to provide material support to a foreign terrorist organization, the Islamic State of Iraq and Levant ("ISIL," aka "ISIS"), Jalloh was sentenced to 11 years in prison. He was released early in 2024 after completing a drug treatment program, although his conviction for terrorism should not have made him eligible for early release. Nor was there an attempt to denaturalize him or deport him back to Sierre Leon. The probation office was required to visit Jalloh only every six months, the last visit being four months before the shooting.
A day after the ODU shooting in 2026, based on probable cause found on Jalloh's cell phone, the FBI raided the home of Kenya Chapman, who it turned out sold the murder weapon to Jalloh. The Glock 44 pistol, which Chapman stole from a vehicle, had a partially-obliterated serial number. Jalloh bought it for $100. In 2021, Chapman had been involved in straw sales of three firearms, two of which were recovered from a homicide shooting. That fall, Chapman was visited by ATF agents, admitted having made false statements in the purchase of the firearms, as certified that he was buying guns for resale, not for personal use. ATF issued Chapman a warning letter rather than prosecuting him. This was well into the Biden Administration, which was implementing its plans to criminalize lawful gun ownership. Now, after the ODU shooting, Chapman claimed not to have any knowledge that Jalloh would commit a crime with the pistol. This time, ATF charged him with making the previous false statements in the purchase of firearms and with engaging in the business of dealing firearms without a license.
After the shooting, the chief prosecutor for Norfolk, Virginia, Commonwealth's Attorney Ramin Fatehi, gave a press conference which made no mention of the shooting as an act of terrorism. Nor did he mention the various gun laws broken by Chapman and Jalloh – theft of firearm, firearm with obliterated serial number, sale of firearm without background check, receipt of firearm by felon, and use of firearm in terrorist murder. Instead, Fatehi claimed, "Until there is the political will to break the spell of the cult of gun absolutism, you will see more incidents like this. So if you are looking for somebody to blame, don't look at anybody up here. Look at our lawmakers who don't have the courage to implement sensible gun control measures. Look to a supreme court that enables them and do something about it." Fatehi is a "progressive" prosecutor who was backed by George Soros-subsidized political action committees.
That attitude raises the issue of whether the ROTC cadets who killed Jalloh might be prosecuted for unlawful homicide, as was Daniel Penny in the New York City subway case. The claim might be that they went beyond self-defense because they could have subdued the shooter by holding him down without stabbing or otherwise injuring him. Any such prosecution would be reprehensible, but there has been a pattern of such prosecutions in recent years. Most obvious examples are the self-defense prosecutions stemming from the 2020 riots, from the indictment of Jake Gardner in Omaha (driving him to suicide) to that of Kyle Rittenhouse in Kenosha, leading to his acquittal by the jury.
In addition, might the cadet who stabbed Jalloh be liable for possession of a knife? A Virginia regulation provides that, "Possession or carrying of any weapon by any person, except a police officer, is prohibited on university property in academic buildings…." Besides firearms, "weapon" means "knives," excluding "knives used for domestic purposes, pen or folding knives with blades less than three inches in length, or box cutters and utility knives…." Failure to remove a knife from the premises when ordered subjects the person to arrest. Moreover, in Virginia it is a crime to carry concealed a dirk, bowie knife, or stiletto knife. The type of knife used by the cadet has not been disclosed.
Two days after the shooting, the Virginia General Assembly sent S749, an enrolled bill banning "assault firearms," to the governor for signature. It will make it a crime for "any person" to buy or sell numerous semiautomatic firearms, such as the popular AR-15-style rifles, as well as standard-capacity magazines that hold over fifteen rounds. It does not apply to possession of firearms by persons with convictions for violent crimes or to the use of firearms in violent crimes.
To paraphrase Commonwealth's Attorney Fatehi, in the future perhaps we'll see if the "supreme court [further] enables" the "cult of gun absolutism" or if it upholds "sensible gun control measures" like S749. In Heller, the Supreme Court held that the Second Amendment protects weapons, including handguns, that are "in common use" or are "typically possessed by law-abiding citizens for lawful purposes." While we don't know if the cadets will be prosecuted for use of a knife to take down Jalloh, in Bruen the Court referred to knives and daggers carried in one's belt as "the smaller medieval weapons that strike us as most analogous to modern handguns."
Among other lessons exemplified here, this act of terrorism would not have occurred but for the failure of the federal and state governments to fulfill their most basic function of protecting the citizenry. At the federal level, Jalloh was naturalized with little apparent vetting, he was released early after being convicted of attempting to provide material support to a foreign terrorist organization, he was not then denaturalized and deported, and his probation officer was required to visit him only every six months. As to Chapman, who sold Jalloh the murder weapon – Jalloh's status as a felon did nothing to stop the sale – ATF should have prosecuted him years before for his straw sales activities.
At the state level, Virginia had declared ODU a "gun-free" zone, guaranteeing that neither the murdered instructor nor the cadets would have a firearm for self defense. We don't know if that would have stopped Jalloh quicker, but it gave Jalloh the foresight that he could gun down "infidels" without any of them shooting back. Virginia's founders like Thomas Jefferson were well familiar with the adage by Cesare Beccaria that: "The laws that forbid the carrying of arms … make things worse for the assaulted and better for the assailants; they serve rather to encourage than to prevent homicides, for an unarmed man may be attacked with greater confidence than an armed man."
What Jalloh didn't count on was that the intended victims would not just freeze like lambs to the slaughter, but instantly attacked him in unison and killed him with a knife and their bare hands, saving their own lives and those of others. While self defense by a single individual is perhaps more often discussed as a legal matter, defense by groups, whether small or large, is a right that is legally justified and ought to be encouraged.
While this column normally concerns cases in litigation, the Supreme Court has repeatedly stated that "individual self-defense is 'the central component' of the Second Amendment right." The heroic ODU cadets who "rendered [the terrorist] no longer alive" exercised this right in its highest form.