United States v. William Mabie, No. 10-3526 (8th Cir. 2011)
Annotate this CaseDefendant was found guilty of three counts of mailing threatening communications, in violation of 18 U.S.C. 876(c), and one count of interstate communication of a threat, in violation of 18 U.S.C. 875(c). Defendant was sentenced to 88 months' imprisonment. Defendant appealed both his conviction and sentence. The court held that the district court did not violate defendant's right to self-representation; the district court did not abuse its discretion in quashing the witness subpoenas that defendant requested; there was sufficient evidence to support his convictions; defendant's conviction under section 876(c) did not violate his First Amendment rights; the district court did not err in assessing a two-level obstruction-of-justice enhancement; and defendant's sentence was reasonable.
Court Description: Criminal case - Criminal law and sentencing. District court did not deny defendant's right of self-representation when it revoked its order allowing him to proceed pro se after he was disruptive in pretrial proceedings and abused the subpoena process; district court did not abuse its discretion when it quashed 34 of defendant's subpoenas; evidence was sufficient to support defendant's convictions for making threatening communications; First Amendment challenge to 18 U.S.C. Sec. 876(c), which criminalizes mailing threatening communications, rejected; nor is the statute void for vagueness; no error in imposing a two-point enhancement under Guidelines Sec. 3C1.1 based on the court's conclusion that defendant perjured himself at trial; sentence was not substantively unreasonable.
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