Michigan's Anti-Terrorism Act defines an act of terrorism as conduct that would constitute a violent felony under state law. Kidnapping, the judges held, is not a violent felony as that term is defined. So kidnapping cannot serve as the predicate act for a material-support conviction - no matter what the defendants did or intended. Both men had also been convicted of committing a felony motivated by gang membership and of possessing a firearm during a felony. "Now, that broken precedent has legally bound this Court of Appeals panel to reverse the convictions of two more dangerous criminals."