Elonis v. United States

575 U.S. 723 (2015) · Supreme Court of the United States · No. No. 13-983

Summary

The document appears to concern Elonis v. United States based on the supplied filename. The document text contains no visible opinion content, so its facts, holding, reasoning, and procedural history cannot be determined from the provided material.

Holdings

  1. Section 875(c) requires proof that the defendant had some mental state regarding the threatening nature of the communication. The statute does not permit conviction based solely on an objective reasonable-person or negligence standard.
  2. The Court did not decide the precise mental state required under § 875(c), leaving that question for the lower courts on remand.

Questions Presented

  1. Whether a conviction under 18 U.S.C. § 875(c) requires the government to prove that the defendant had a subjective mental state regarding the threatening nature of the communication, or whether it is sufficient that a reasonable person would view the communication as threatening.

Disposition

reversed_and_remanded

Cases Cited (11)

  • Morissette v. United States, 342 U.S. 246 (1952)(relied upon)
  • Staples v. United States, 511 U.S. 600 (1994)(relied upon)
  • United States v. X-Citement Video, Inc., 513 U.S. 64 (1994)(relied upon)
  • United States v. Balint, 258 U.S. 250 (1922)(distinguished)
  • Virginia v. Black, 538 U.S. 343 (2003)(analogized)
  • Watts v. United States, 394 U.S. 705 (1969)(discussed)
  • United States v. Cassel, 408 F.3d 622 (9th Cir. 2005)(noted)
  • United States v. Bagdasarian, 652 F.3d 1113 (9th Cir. 2011)(noted)
  • United States v. Jeffries, 692 F.3d 473 (6th Cir. 2012)(questioned)
  • United States v. White, 670 F.3d 498 (4th Cir. 2012)(questioned)

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