Whether federal criminal offenses that include a substantive nexus between a charged murder and the defendant's alleged involvement in a criminal organization require specific proof of the defendant's 'animating purpose'

QUESTION PRESENTED FOR REVIEW 1. Whether federal criminal offenses that include, as an element, a substantive nexus between a charged murder and the defendant’s alleged involvement in a criminal organization, including 18 U.S.C. § 1959(a)(1), 21 U.S.C. § 848(e)(1)(A), and 18 U.S.C. § 924G)(1), require specific proof that, at the time of the murder, the defendant’s “animating purpose” was to advance the interests of or secure his position within the criminal organization. i RELATED CASES United States v. Santiago-Ortiz, No. 17 Cr. 149-1 (LAK), U.S. District Court for the Southern District of New York. Judgement entered December 20, 2018. United States v. Santiago-Ortiz, No. 18-3830, U.S. Court of Appeals for the Second Circuit. Summary Order issued December 18, 2019. Petition for rehearing denied January 23, 2020. ii