Jeffries v. United States
Petition for certiorari denied on October 7, 2013
Issue: Whether, in light of the plain meaning of “threat” and the constitutional rule of Virginia v. Black, a conviction under 18 U.S.C. § 875(c) for “transmit[ing] in interstate or foreign commerce any communication containing . . . any threat to injure the person of another” requires proof of a subjective or specific intent to threaten.