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Supreme Court of the United States - 135 S. Ct. 2001
Tags: Mens rea, threat, reasonable person
tl;dr:
Man makes threatening posts on facebook. Charged with making interstate threats, but reversed by Supreme Court because lacked mens rea requirement.Video Summary
Case Summary
In the Elonis v. United States case (2015), the defendant faced charges for posting threatening messages on Facebook, aimed at his separated wife, co-workers, children, and law enforcement officers. The Supreme Court focused on whether the defendant could be convicted under the law (18 U.S.C. § 875 ©) without proving his intention to threaten anyone. Lower courts used an objective standard based on how a reasonable person would understand the defendant's words, but the defendant argued this violated his First Amendment rights.
In an 8-1 decision, the Supreme Court overturned the conviction, stating that the objective standard wasn't enough for a conviction under Section 875 ©. Proof of the defendant's mental state was necessary. The court didn't specify the level of mental state required, suggesting it could involve purpose or knowledge. They didn’t address the First Amendment issue.
This case is important as it clarified the mens rea (mental element) required for federal threat laws and other speech-related crimes. It also raised questions about the distinction between protected speech and unprotected "true threats," particularly in online communication where context and tone may be unclear or misinterpreted.
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The case involves a conviction for transmitting threatening communications on Facebook. The issue is whether the defendant must be aware of the threatening nature of the communication and whether the First Amendment requires such a showing. The lower court erred by instructing the jury to find that Elonis communicated what a reasonable person would regard as a threat. The Supreme Court held that a true threat is a statement that intends to inflict bodily injury or take the life of an individual, and can be reasonably interpreted as such. Although the statute does not specify any required mental state, a defendant must have a blameworthy state of mind before being found guilty. The Court has consistently required a defendant to have knowledge of the crucial elements that separate legal innocence from wrongful conduct.
The legal case concerns the interpretation of the mental state required for conviction under 18 U.S.C. § 875(c), which criminalizes the transmission of a communication that is a threat to injure another person. The Court found the jury instructions to be defective for requiring only negligence in conveying a threat, but did not clarify the necessary intent. Justice Alito suggests that a "threat" in § 875(c) can be defined as a statement that reasonably expresses an intention to harm another person, and to secure a conviction, it must be shown that the defendant was at least reckless as to whether the transmission met that requirement. The Court presumes that an offense like that created by § 875(c) requires more than negligence with respect to a critical element, and that a serious offense against the person that lacks any clear common-law counterpart should be presumed to require more.
The legal issue in this case is the mental state required to convict Elonis for making threatening posts on social media. The author of the dissenting opinion believes that the lower court's decision to use the general-intent standard was correct, as the communications posted by Elonis were genuine threats that are not protected by the First Amendment. The author opposes imposing a higher mental-state requirement and argues that general intent does not require any mental state regarding the fact that certain words meet the legal definition of a threat. The author believes that Elonis was properly convicted under the requirements of § 875(c) and must address his argument that his threatening posts were protected by the First Amendment.
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