United States v. C.S., No. 19-1254 (3d Cir. 2020)
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C.S., age 17, made threatening statements to a confidential informant in an online chatroom dedicated to discussing terroristic attacks. Law enforcement searched C.S.’s home and cell phone. In his home, agents discovered assault rifles, ammunition, a crossbow, a headscarf, smoke bombs, grenade casings, military-style ammunition vest and gear, and a long-bladed knife. His cell phone revealed Internet searches, literature about making explosives, Islamic Jihadi propaganda videos depicting beheadings, and photos of C.S. posing with his assault rifle while wearing military gear and headscarf. C.S. was adjudicated delinquent, 18 U.S.C. 875(c). During several conversations, C.S. made threats against a local church. Although juvenile proceedings are usually sealed, the court permitted the government to notify the church that it was the subject of a threat and that the party who communicated the threat had been prosecuted. The order did not identify C.S.
The Third Circuit affirmed. C.S.’s statements qualified as threats under section 875(c). A rational factfinder could find that a reasonable person could consider C.S.’s statements to be “a serious expression of an intent to inflict bodily injury.” The court did not violate the confidentiality provisions of the Juvenile and Delinquency Prevention Act of 1974, 18 U.S.C. 5031-5038), in allowing the government to notify the church of the threats and acted well within its discretion in issuing the notification order.
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