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Elonis v. United States
United States Supreme Court
135 S. Ct. 2001 (2015)
Elonis (defendant) posted violent language directed at his estranged wife online. The United States (plaintiff) charged Elonis with making interstate threats in violation of 18 U.S.C. § 875(c). Section 875(c) did not contain any required mens rea. Elonis argued he did not violate section 875(c) because he did not intend to threaten anyone. The district court instructed the jury to use a reasonable person standard in determining whether Elonis’s postings constituted threats. The jury convicted Elonis. The court of appeals affirmed, holding that section 875(c) did not require intent to communicate a threat, but rather only an intent to communicate words that a reasonable person would deem a threat. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Roberts, C.J.)
Concurrence/Dissent (Alito, J.)
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