Elonis requires intent instruction under 18 USC 875 – Fourth Circuit
US v. White. White was convicted of three counts of violating 18 U.S.C. 875(b) for sending threats in interstate commerce with an intent to extort, and one lesser included offense under 18 U.S.C. 875(c) for sending threats without the intent to extort. White appealed the conviction, arguing, among other theories, that the trial court erred in its …
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