United States v. Chapman, No. 16-1810 (3d Cir. 2017)Annotate this Case
While serving a state prison sentence in 2006, Chapman wrote a letter, intercepted by prison staff, threatening to kill President Bush. In an interview with Secret Service agents, Chapman admitted that he wanted to kill the President and made additional threats. He pled guilty to threatening the President, 18 U.S.C. 871(a). and was sentenced to 30 months’ imprisonment. In 2007, Chapman mailed a letter to a federal judge, including threats against the judge and other court staff. Chapman was sentenced to an additional 48 months imprisonment under 18 U.S.C. 876(c). Chapman was released from custody in 2014. He violated the terms of his supervised release and received a sentence of 11 months’ imprisonment. While serving that sentence, Chapman mailed a letter with threats against the federal prosecutor who handled Chapman’s revocation proceedings and the probation officer involved with Chapman’s case. He pled guilty under 18 U.S.C. 876(c) and was sentenced to 70 months, at the low end of the U.S.S.G. range. The Third Circuit affirmed application of the career offender enhancement to his sentence calculation, rejecting an argument that his convictions pursuant to 18 U.S.C. 876(c) did not qualify as crimes of violence. That section proscribes mailing a communication containing a threat to injure a person.