Legal Case Summary

Case Details
Case ID 09dcb2ec-7eb8-4f0c-aabe-aa06a4acca4d
Body View case body.
Case Number No. 13-983
Decision Date Jun 01, 2015
Hearing Date Dec 01, 2014
Decision The Supreme Court reversed the judgment of the Appellate Court and remanded the case for further proceedings consistent with the majority opinion. The Court held that conviction for 'communicating a threat to injure the person of another' under 18 U.S.C. §875(c) requires proof that the accused intended to issue a threat or was aware that his communication would be viewed as a threat. The majority opinion rejected the 'reasonable person' standard that had been applied, which had reduced the culpability of the accused to negligence. The Court emphasized that a guilty mind is a necessary element in criminal law and that a mere negligent standard is insufficient for criminal liability. The case addresses the complexities of free speech in the context of social media and the need for a clearer standard regarding the mental state required for criminal threats.
Summary In the landmark case of Elonis v. United States, the Supreme Court examined the legal implications of threats communicated via social media. The case arose when Anthony Douglas Elonis was convicted for posting violent rap lyrics on Facebook, which were perceived as threats against his estranged wife, co-workers, and law enforcement. The Court's ruling clarified that, under 18 U.S.C. §875(c), a conviction for communicating a threat requires the prosecution to prove that the defendant intended to convey a true threat or was at least aware that the communication would be interpreted as such. This case is pivotal in understanding the intersection of free speech and criminal liability, particularly in the digital age where social media plays a significant role in communication. The decision underscores the importance of a defendant's mental state and reaffirms the principle that negligence alone cannot suffice for criminal liability. The implications of this ruling resonate within the ongoing debates surrounding the regulation of speech on social media platforms and the protection of individuals from genuine threats of violence.
Court Supreme Court of UK
Entities Involved Not available
Judges JOHN G. ROBERTS, C.J., ANTONIN SCALIA, ANTHONY M. KENNEDY, RUTH BADER GINSBURG, STEPHEN G. BREYER, SONIA SOTOMAYOR, ELENA KAGAN, SAMUEL ANTHONY ALITO, CLARENCE THOMAS
Lawyers Not available
Petitioners ANTHONY DOUGLAS ELONIS
Respondents UNITED STATES
Citations 2015 SLD 2098, 2015 SCMR 1192
Other Citations United States v. Balint, 258 U. S. 250, 251 (1922), Staples v. United States, 511 U.S. at 606-607, Rogers v. United States, 422 U.S. 35, 47 (1975), Cochran v. United States, 157 U.S. 286, 294 (1895), Morissette v. United States, 342 U.S. 252 (1952), Hamling v. United States, 418 U.S. 87 (1974), United States v. Darby, 37 F. 3d 1059, 1066 (CA4 1994), United States v. Jeffries, 692 F. 3d 473, 478 (CA6 2012)
Laws Involved 18 U.S.C. §875(c)
Sections Not available