A defendant threatened his wife, coworkers and law enforcement on Facebook. The FBI investigated and the defendant was charged and convicted for transmitting "any communication containing any threat . . ." in interstate commerce.
The U. S. Supreme Court reversed the conviction because the trial judge did not include any mention of criminal intent in the jury instructions. The Court held that in some cases, a general requirement that a defendant act knowingly is sufficient, but where such a requirement would not protect an innocent actor, the statute must be read to require specific intent.
This decision is important because it further erodes the government's ability to prosecute people without proving a culpable mental state. For instance, some prosecutors charge defendants who accidentally carry a firearm into the airport. This decision will help protect people from being convicted when they only act negligently and not intentionally.
