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Grooming Extremism: The FBI’s Role in Criminalizing Youth with Disabilities
Photo by Daniel Roberts via pixabay
In 2021, an adult initiated an online relationship with sixteen-year-old Mateo Ventura—a teenager with special needs.[1] For over two years, as his classmates bullied him, the socially isolated boy increasingly communicated with the adult online, who instructed him not to tell his family about their conversations.[2] During that period, pursuant to the adult’s instructions, Ventura sent the adult several twenty-five-dollar Google Play gift certificates, totaling over $900. Finally, in June 2023, the Federal Bureau of Investigation (FBI) made an arrest widely reported by local news media.[3] The FBI had arrested Mateo Ventura, soon after his eighteenth birthday, alleging that his transfer of twenty-five-dollar Google Play gift certificates made him an “international terrorist financier.”[4]
The adult who corresponded with Ventura since he was a minor was, in fact, an undercover FBI counterterrorism agent.[5] Sidestepping the unsettling dynamic between an adult and a minor with developmental disabilities, the government argued its sting operation was justified because it considered sixteen-year-old Ventura a potential terrorist at risk of joining ISIS.[6]
The operation against Ventura is not an anomaly. In the landscape of FBI counterterrorism sting operations, Ventura’s case exemplifies a familiar pattern. First, a socially isolated teenager with developmental disabilities and mental health obstacles posts provocative or extreme religious content online, capturing the FBI’s attention. Undercover FBI agents then develop a relationship with the teenager under false pretenses. Finally, after a years-long sting operation, the FBI arrests the teenager shortly after their eighteenth birthday for attempting to commit a “national security” offense.[7]
The government portrays these sting operations as successful foils of sinister terrorism schemes, necessary to safeguard national security.[8] Journalists and litigators, however, have increasingly pushed back against this narrative, exposing the questionable tactics underlying many of these stings: the grooming of youth with disabilities––most often minors from a Muslim background or recent converts to Islam––to commit terrorism-related offenses.
In 2023, the same year as Ventura’s arrest, The Intercept reported that online undercover agents “groomed” two other teenagers with mental illnesses and disabilities during years-long counterterrorism sting operations before arresting them––one while he was reading Diary of a Wimpy Kid.[9] These sting operations deeply impacted the families involved. One mother recounted begging for mental health intervention to keep her son out of the justice system, only for undercover agents to step in the moment he turned eighteen. She reflected: “I lost him. He is gone behind the walls of steel and indifference.”[10]
Criminal defense attorneys in similar terrorism cases have exposed how the FBI’s targeting of minors online is ongoing.[11] Instead of warning families about their teenagers’ concerning online behavior or offering mental health resources, law enforcement groomed these teenagers, encouraging them to commit crimes they otherwise lacked the resources to carry out. As the sophistication and proliferation of surveillance technologies increases, the FBI’s disturbing pattern of targeting vulnerable Muslim minors is particularly concerning—especially since many of these operation details remain shielded from public scrutiny in the name of national security.[12] All this prompts the question: how is this legal?
The Questionable Rationale Underpinning These Sting Operations
In theory, sting operations identify individuals who have a “propensity” to engage in criminal activity.[13] Under the criminal justice theory of incapacitation, sting operations enable law enforcement to arrest and incarcerate those “predisposed” to committing violence, effectively removing them from society before they can act.[14] For example, sting operations targeting child sex offenders utilize online undercover agents posing as minors. Proponents of these operations argue that such criminal behavior is undeterrable—the only way to protect society is to identify and incapacitate these dangerous individuals before they can actualize harm.[15] Sting operations for terrorism offenses follow a similar rationale, hinging on the belief that certain individuals are predisposed to committing terrorism offenses and cannot be deterred.[16]
This rationale is murky for two reasons. First, law enforcement’s identification of those “predisposed” to committing terrorism offenses essentially constitutes racial and religious profiling.[17] In consequence, the FBI engages in fishing expeditions in Muslim communities, targeting those with factors making them more susceptible to entrapment—factors such as mental illness and disabilities, indigent status, or recent conversion to Islam.[18]
Second, the assertion that these entrapped teenagers cannot be deterred also lacks evidence, especially given how young they are.[19] Ironically, while sting operations are often defended as protecting minors, here they function as a mechanism to groom certain youth—specifically those religiously profiled as potential terrorists—into committing crimes. Prior to FBI involvement, the teenagers in these cases engaged with questionable social media and internet activity—speech that, by itself, is not a crime. After all, there are plenty of young teenagers on the internet posting provocative, dissident, offensive, and even extremist content. Importantly, however, the teenagers in these cases were dependent on their families and did not have the resources to orchestrate criminal schemes by themselves. Judge Sharon Johnson Coleman recognized as much when she granted a lenient sentence to Adel Daoud–a young man with developmental disabilities entrapped by FBI undercover agents at age seventeen–only for the decision to be overturned on appeal.[20] Judge Coleman noted that Daoud–an “awkward young man with few friends”–was quickly drawn to the thirty-eight-year-old FBI agent who entrapped him, highlighting the concerning power dynamic at play in these operations.[21]
If not criminalization, then what?
Given the dubious logic underlying these sting operations, pushing back against the criminalization of marginalized and vulnerable youth is imperative. While legal doctrines, such as the entrapment defense and outrageous government conduct, may exist as potential avenues for relief for vulnerable defendants, in practice, they very rarely succeed.[22] As such, there needs to be widespread demand for transparency and a systemic reckoning with how counterterrorism operations can target vulnerable minors.
Many public-interest-minded legal advocates recognize that surveillance and punitive measures disproportionately criminalize children of color, feeding into the harmful school-to-prison pipeline.[23] As a result, advocacy efforts focus on moving away from policing and instead toward increasing children’s access to mental health counseling and other holistic care. The criminalization of Muslim youth, often with developmental and intellectual disabilities, benefits from a similar analysis. In the years FBI agents spent provoking vulnerable youth into committing manufactured crimes, that time—and the resources invested with it—could have been redirected to holistic care and community resources to help these teenagers lead more productive and happier lives.
Importantly, as policy shifts away from criminalization, interventionist measures must not take the form of the problematic Countering Violent Extremism (CVE) programs, which notoriously served as fronts for intelligence-gathering in Muslim communities after 9/11.[24] If the goal is safety rather than criminalizing the most vulnerable within a religious minority, we must invest in community programs addressing the root factors driving crime, not expand law enforcement. Investing in equitable, culturally competent mental health care provides a path forward. Humzah Mashkoor was sixteen years old when the FBI agents approached him, conversing with him about his mental health struggles, family problems, and desire for romantic partnership.[25] Imagine if, in that year-and-a-half of surveillance and emotional exploitation, Mashkoor had benefited from competent counseling and mental health care instead undercover agents posing as confidants.
In the interim, until systemic change is achieved, criminal justice system actors with discretionary power should critically inquire: who exactly are these sting operations protecting when they prey on the most vulnerable?
[1] Murtaza Hussain, The FBI Groomed a 16-Year-Old with “Brain Development Issues” to Become a Terrorist, The Intercept (June 15, 2023), https://theintercept.com/2023/06/15/fbi-undercover-isis-teenager-terrorist/.
[2] Id. (quoting the criminal complaint where the undercover, posing as an ISIS member who spoke broken English, told Mateo Ventura, “U must no talk about what said here or intention to anyone. No tell family”).
[3] Jamy Pombo Sesselman, 18-Year-Old Wakefield, Massachusetts Man Accused of Trying to Donate Money to ISIS Terrorist, WCVB Channel 5 (Oct. 18, 2023), https://www.wcvb.com/article/18-year-old-wakefield-massachusetts-man-accused-of-trying-to-donate-money-to-isis-terrorists/45568838 (reporting Mateo Ventura as an “18-year-old man” who tried to donate thousands of dollars to ISIS).
[4] Hussain, supra note 1.
[5] Id.
[6] But cf. Islamic State Group Defeated as Final Territory Lost, US-Backed Forces Say, BBC (Mar. 23, 2019), https://www.bbc.com/news/world-middle-east-47678157 (reporting that by 2019, ISIS was already in serious decline); see Hussain, supra note 1 (noting that in 2023 Mateo Ventura had started to turn against the undercovers, even reaching out to law enforcement to report the undercovers for terrorism);
[7] See Sahar Aziz, Race, Entrapment, and Manufacturing “Homegrown Terrorism,” 111 Geo. L.J. 381, 441 (2023) (finding that in a survey of 646 terrorism-related cases, at least 155 suggested that the defendant had mental health concerns or disabilities).
[8] See Press Release, U.S. Att’y’s Off., Dist. of Mass., Massachusetts Man Arrested for Knowingly Concealing the Source of Material Support or Resources to a Foreign Terrorist Organization (June 8, 2023), https://www.justice.gov/usao-ma/pr/massachusetts-man-arrested-knowingly-concealing-source-material-support-or-resources.
[9] Murtaza Hussain, After His Mother Asked for Help, FBI Terrorism Sting Targets Mentally Ill Teen, The Intercept (July 31, 2023), https://theintercept.com/2023/07/31/fbi-isis-sting-mentally-ill-teen/; see also Murtaza Hussain, Undercover FBI Agents Helped Autistic Teen Plan Trip to Join ISIS, The Intercept (Jan. 10, 2024), https://theintercept.com/2024/01/10/fbi-sting-isis-autistic-teen/.
[10] Hussain, After His Mother Asked for Help, supra note 9.
[11] See A Revert’s Fight Against Discriminatory Prosecution, The Muslim Legal Fund of America, https://mlfa.org/cases/a-reverts-fight-against-discriminatory-prosecution/ (last visited July 22, 2026) (reporting that during Jason Fong’s first criminal trial, which ended in a mistrial, litigators exposed how counterterrorism undercover operatives had targeted a Muslim child; following the mistrial, the government withdrew its primary undercover witness, preventing further questioning of undercover tactics, and offered a plea deal instead).
[12] See FBI v. Fazaga, 595 U.S. 344, 356–57 (2022).
[13] Bruce Hay, Sting Operations, Undercover Agents, and Entrapment, 70 Mo. L. Rev. 387, 392 (2005).
[14] Id. at 393.
[15] Id.
[16] Id. at 396 (asserting that individuals predisposed to committing terrorism offenses “may be undeterred by the threat of criminal penalties . . . the only way to prevent them from inflicting catastrophic losses is to catch them before they strike”).
[17] See Illusion of Justice: Human Rights Abuses in US Terrorism Prosecutions, Human Rights Watch (July 21, 2014), https://www.hrw.org/report/2014/07/21/illusion-justice/human-rights-abuses-us-terrorism-prosecutions (reporting that informants and agents often choose counterterrorism sting operation targets based on religious or political beliefs—indicators lacking empirical basis).
[18] See Aziz, supra note 7, at 422 (articulating how these targeted stings operate from a circular logic of predisposition—the factors that justify the stings will consequentially defeat any entrapment defense).
[19] Id. at 389 (highlighting that assumptions regarding deterrence in terrorism cases rests upon dubious radicalization theories); see Richard Mendel, Why Youth Incarceration Fails: An Updated Review of the Evidence, The Sent’g Project (Mar. 1, 2023), https://www.sentencingproject.org/reports/why-youth-incarceration-fails-an-updated-review-of-the-evidence/ (reporting that youth incarceration often produces counterproductive outcomes).
[20] Judge Sentences Would-Be Chicago Bar Bomber to 16 Years, WTTW (May 6, 2019), https://news.wttw.com/2019/05/06/adel-daoud-chicago-prison-sentence-16-years (reporting that Judge Coleman stated that Daoud did what “teenage boys do . . . talk big”).
[21] Id.
[22] See Aziz, supra note 7, at 422 (highlighting how racial and religious biases often will constitute ‘predisposition,’ defeating the entrapment defense when defendants are Muslim); see Eve A. Zelinger, The Outrageous Government Conduct Defense: An Interpretive Argument for its Application by SCOTUS, 46 Hastings Const. L.Q. 153, 177 (2018) (noting the lack of case law for the outrageous government conduct defense because it is seldom raised and, even when litigated, is usually defeated).
[23] Richard Mendel, Back-to-School Action Guide: Re-Engaging Students and Closing the School-to-Prison Pipeline, The Sentencing Project (Aug. 31, 2021), https://www.sentencingproject.org/reports/back-to-school-action-guide-re-engaging-students-and-closing-the-school-to-prison-pipeline/.
[24] See “Countering Violent Extremism,” a Flawed Approach to Law Enforcement, ACLU Mass., https://www.aclum.org/countering-violent-extremism-flawed-approach-law-enforcement/ (last visited July 22, 2026).
[25] Aziz, Undercover FBI Agents Helped Autistic Teen Plan Trip to Join ISIS, supra note 9.