United States v. Haas, No. 20-3269 (7th Cir. 2022)
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Haas believes that Jews are responsible for crimes against humanity, that Israel is “the biggest racist organization on the planet,” and that anyone who supports Israel or Jews is a traitor who deserves to die. After posting death threats against former U.N. Ambassador Nikki Haley on her Instagram page, Haas was visited by diplomatic security officers. He reiterated his violent message during that conversation and then posted vile, anti-Semitic statements on a Russian social media website. An FBI agent questioned him about the new threats, but Haas made threats against the agent via texts and voicemails. He was convicted for transmitting threats in interstate commerce and for the threats against the FBI agent and was sentenced to 51 months in prison.
The Seventh Circuit affirmed. Only a multiplicity challenge to the indictment was properly preserved. The allowable unit of prosecution under 18 U.S.C. 115 is the individual threat, not some broader scheme or plot to threaten. After a “fact-intensive inquiry,” the court concluded that the individual threats were properly charged separately. Contentions that the government’s evidence was insufficient to support the verdict, that the indictment was constructively amended, and that some counts were improperly grouped for sentencing, were all forfeited and do not undermine the district court’s judgment.
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