United States v. Oliver, No. 20-1654 (1st Cir. 2021)
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The First Circuit affirmed Defendant's conviction of two counts of mailing threatening communications through the United States Postal Service, in violation of 18 U.S.C. 876(c), holding that the evidence was sufficient to support the verdict.
After a jury found Defendant guilty of both counts of mailing threatening communications Defendant moved for a judgment of acquittal. The district court denied the motion, concluding that the evidence sufficed to permit a rational jury to find Defendant guilty of both counts. On appeal, Defendant challenged the sufficiency of the evidence with respect only to the third element of the offense. The First Circuit affirmed, holding that a rational jury could have found that Defendant knew his statements would be interpreted as true threats of physical harm.
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