Case ID |
09dcb2ec-7eb8-4f0c-aabe-aa06a4acca4d |
Body |
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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
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Entities Involved |
Not available
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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
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Lawyers |
Not available
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Petitioners |
ANTHONY DOUGLAS ELONIS
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Respondents |
UNITED STATES
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Citations |
2015 SLD 2098,
2015 SCMR 1192
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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)
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Laws Involved |
18 U.S.C. §875(c)
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Sections |
Not available
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