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United States v. Coss

United States Court of Appeals for the Sixth Circuit
677 F.3d 278 (2012)


Facts

The federal government (plaintiff) prosecuted Allison Lenore Coss and Scott Edward Sippola (defendants) for transmitting, by means of interstate communication and "with intent to extort," a "threat" to injure the reputation of well-known actor John Stamos, in violation of 18 U.S.C. § 875(d). The trial evidence established that Coss and Sippola, who met in 2008, possessed photographs taken of Coss with Stamos at a party in 2004. In September 2009, Coss and Sippola set up an email account in the fictitious name of "Jessica." "Jessica" emailed Stamos, informing him that he had impregnated her and that she had compromising photographs that she was sure Stamos would not want "to get out." A month later, Coss and Stamos set up another email account, this time in the fictitious name of "Brian," who emailed Stamos and notified him that "Brian" planned to sell photographs of Stamos' 2004 encounter with Coss, unless Stamos bought the photographs for $680,000. Stamos notified federal authorities, who arrested Coss and Sippola after Stamos's associate delivered the purchase money to them. The jury convicted Coss and Sippola. On appeal to the Sixth Circuit Court of Appeals, the pair contested their conviction on the grounds that their actions were not unlawful and that § 875(d) was unconstitutionally void for vagueness.

Rule of Law

Issue

Holding and Reasoning (Moore, J.)

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