Drawing a line between therapy and threats: In Plain English
Posted Mon, November 24th, 2014 3:31 pm by Amy Howe
Protesting at the funeral of a fallen soldier. Lying about your military record. Violent video games for children. Making videos about dogfighting. In the past few years, the Supreme Court has held that the First Amendment protects all of these forms of expression, even when very unpopular or offensive. Next week the Justices will hear oral arguments to determine whether Anthony Eloniss Facebook posts, which left his ex-wife extremely scared and an FBI agent worried about her familys safety, are entitled to the same kind of protection. Lets talk about Elonis v. United States in Plain English.
Eloniss legal troubles date back to 2010, when his wife left him, taking their two young children with her. He began to post lyrics from popular songs on Facebook, and he soon moved on to post his own, sometimes violent, rap lyrics. As part of his posts, Elonis included disclaimers about how his lyrics were merely fictitious, and that he was just exercising his constitutional right to freedom of speech. He also sometimes included links to the Wikipedia entry on the First Amendment and even the text of the First Amendment itself.
In the fall of 2010, Eloniss Facebook posts included several that discussed harming his ex-wife. One post was a take-off on a comedy routine available on YouTube: Elonis asked his Facebook friends whether they knew that it was illegal for him to say that he wanted to kill his ex-wife, and he added that it would be incredibly illegal to suggest that someone could kill his ex-wife by firing a mortar launcher from the cornfield behind her house. A day later, Elonis put up a post about shooting a kindergarten class.
These posts earned Elonis a visit from an FBI agent. After the visit, he posted about that encounter too, suggesting in rap lyrics that he had strapped a bomb to his body and would have detonated it if he had been arrested. This post was apparently the last straw for the FBI: a few weeks later, Elonis was arrested and charged with violating 18 U.S.C. 875(c), which makes it a crime to communicate threats in interstate commerce for example, over the Internet.
Elonis claimed that the charges against him should be dismissed because you can only violate the law if you intend to harm someone. And he didnt have any plans to hurt his ex-wife, the FBI agent, or anyone else: his rap lyrics and venting about his problems on Facebook just made him feel better. But if he can be convicted without any intent to hurt anyone, he added, that would violate the First Amendment. A federal trial court rejected both of his arguments. Instead, it instructed the jury, it could find Elonis guilty if the average person, looking at a statement objectively, would believe that it was intended to be a threat. The jury convicted Elonis, and he was sentenced to nearly four years in prison.
As Elonis emphasized in his Facebook posts, the First Amendment protects a right to free speech. But that right is not unlimited; the classic example is that you cant shout Fire! in a crowded movie theater when there is actually no fire, because the resulting chaos could lead to injuries or even death. The Supreme Court has held that the First Amendment also does not protect true threats, but it has not specifically said how courts should decide what is (or is not) a true threat. This case could give it that opportunity.
In his briefs at the Supreme Court, Elonis argues that a threat by its very nature requires an intent to cause fear. Because the whole point of a crime, he says, is that the defendant meant to do something wrong, the Court has interpreted criminal laws as requiring a wrongful intent even when they did not explicitly do so. Making it a crime to threaten someone even if you didnt intend to hurt them, he contends, would cause people not to speak at all, because they would be worried about whether they could go to jail based on a jurys possible misinterpretation of their comments. This is particularly true, he concludes, when you are talking about alleged threats on social media and email, where nuance and tone matter so much and its so easy to misconstrue what someone says.
The federal government counters that, as the trial court in this case instructed the jury, courts should determine whether something is a true threat by looking at whether an average person would interpret the statement as reflecting a serious intent to harm someone. The government emphasizes that courts and juries can and should look at the context in which the alleged threat was made, and at the reactions of the people who heard the alleged threat, but they should not consider whether the defendant himself actually intended to carry out the threat. This, the government explains, is because even if Elonis didnt intend to harm his ex-wife or the FBI agent, they were still afraid and their lives were still disrupted: the First Amendment doesnt protect him even if he knew that he didnt mean to carry out the threats.
We dont generally think of the Justices of the Supreme Court as especially savvy about technology. They did acquit themselves well last Term, in a case involving whether police need a warrant to search someones cellphone after they arrest him. But that may have been easier because they all have cellphones. It is far less likely that any of these nine intensely private public figures are on Facebook or any other form of social media, so it will be interesting to watch them grapple with these issues.
Original post:
Drawing a line between therapy and threats: In Plain English
- At FIU stop, DeSantis discusses First Amendment rights in wake of federal judge ruling in favor of anti-ICE protesters - WSVN - August 27th, 2026 [August 27th, 2026]
- Commentary: The First Amendment is more than the right to speak - Lake Oswego Review - August 27th, 2026 [August 27th, 2026]
- Trumps Unholy War on the First Amendment - Progressive.org - August 27th, 2026 [August 27th, 2026]
- Stars and Stripes staffers sue Pentagon over firings alleging First Amendment violations - The Independent - August 27th, 2026 [August 27th, 2026]
- Man arrested at Berkeley County gas station says his First Amendment rights were violated - Live 5 News - August 27th, 2026 [August 27th, 2026]
- Composer-Pianist Vijay Iyer to Perform at The Forever War Symposium - | Knight First Amendment Institute - August 27th, 2026 [August 27th, 2026]
- How Do We Aggressively Lobby for Press Freedom Legislation in a Post-Trump World? - | Knight First Amendment Institute - August 27th, 2026 [August 27th, 2026]
- Federal judge says FIU violated first amendment rights of anti-ICE student protesters - Creative Loafing Tampa - August 27th, 2026 [August 27th, 2026]
- Trump Sued for Selling Early Access to Truth Social Posts: First Amendment Analysis - Freedom Forum - August 22nd, 2026 [August 22nd, 2026]
- Students, ACLU argue FIU violated First Amendment rights after doling out punishments for ICE protests - WSVN - August 22nd, 2026 [August 22nd, 2026]
- Did this field trip to a mosque violate the First Amendment? A group of Palo Alto parents think so. - The Forward - August 22nd, 2026 [August 22nd, 2026]
- Second Circuit Says You Have a First Amendment Right to Film Police in Public - Fstoppers - August 22nd, 2026 [August 22nd, 2026]
- Column: Lets celebrate ALL of the First Amendment, not part - The Daily Tar Heel - August 22nd, 2026 [August 22nd, 2026]
- Jury Says The New York Times Defamed Alabama Basketball Player With Incorrect Story About Shooting - First Amendment Watch - August 22nd, 2026 [August 22nd, 2026]
- Disney and ABC filed a First Amendment lawsuit against the FCC - Morning Brew - August 22nd, 2026 [August 22nd, 2026]
- Five Standout Claims In ABCs First Amendment Lawsuit Against The FCC - Deadline - August 22nd, 2026 [August 22nd, 2026]
- Judge weighs First Amendment case involving FIU student protest - CBS News - August 22nd, 2026 [August 22nd, 2026]
- ABC sues FCC claiming first amendment violation - WBKO - August 22nd, 2026 [August 22nd, 2026]
- ABC sues FCC over license reviews, citing First Amendment rights - WRTV - August 22nd, 2026 [August 22nd, 2026]
- Rich Lenkov on murder trials, cocaine trafficking, and a First Amendment showdown - WGN Radio 720 - August 22nd, 2026 [August 22nd, 2026]
- FCC Boss Brendan Carr Says Disneys First Amendment Lawsuit Is Without Merit - Media Play News - August 22nd, 2026 [August 22nd, 2026]
- Judge Plans October Hearing In ABCs First Amendment Lawsuit Against FCC, Says It Will Be Sooner If Agency Takes Action On Licenses - Yahoo - August 22nd, 2026 [August 22nd, 2026]
- Antithesis of Our First Amendment: Families Ask Supreme Court to Toss Texas Ten Commandments Law - Alaska Native News - August 22nd, 2026 [August 22nd, 2026]
- ABC Has Filed a First Amendment Lawsuit Against the FCC After Trump Admin Goes After Network - IMDb - August 22nd, 2026 [August 22nd, 2026]
- ABC Has Filed a First Amendment Lawsuit Against the FCC After Trump Admin Goes After Network - Just Jared - August 22nd, 2026 [August 22nd, 2026]
- Disney Takes on Trump: Can ABC Win Its First Amendment Suit Against the FCC? | Analysis - IMDb - August 22nd, 2026 [August 22nd, 2026]
- First Amendment group rebukes San Joaquin RTD director over threat to sue public critics - Stocktonia - August 14th, 2026 [August 14th, 2026]
- Does the First Amendment Protect Freedom From Religion? - First Liberty Institute - August 14th, 2026 [August 14th, 2026]
- Opinion | Trumps attack on a think tank is an affront to the First Amendment - The Washington Post - August 14th, 2026 [August 14th, 2026]
- Dining hall workers union sues ASU, alleging First Amendment violations - The State Press - August 14th, 2026 [August 14th, 2026]
- ACLU-SC to SC Arts Commission: Respect the First Amendment - ACLU of South Carolina - August 14th, 2026 [August 14th, 2026]
- How does the First Amendment govern liability for AI? - Free Speech Center - August 14th, 2026 [August 14th, 2026]
- Judge Orders Massachusetts Sheriff To Hand ICE Detainee Records to ACLU - First Amendment Watch - August 14th, 2026 [August 14th, 2026]
- Masked men practicing First Amendment right to video in public antagonize residents at post office in Pleasanton - Pleasanton Weekly - August 14th, 2026 [August 14th, 2026]
- How the First Amendment protects our 5 freedoms and why its in danger - The Seattle Times - August 14th, 2026 [August 14th, 2026]
- Dining hall workers suing ASU over First Amendment right to protest working conditions - KTAR News 92.3 FM - August 14th, 2026 [August 14th, 2026]
- Lawsuit Seeks To Ban Trump Media From Charging for Early Access to Presidents Posts on US Policy - First Amendment Watch - August 14th, 2026 [August 14th, 2026]
- Judge Dismisses Trump Administration Lawsuit Alleging Antisemitism at Harvard University - First Amendment Watch - August 14th, 2026 [August 14th, 2026]
- Meta To SCOTUS: Addiction Suits Barred By First Amendment, Section 230 - Yahoo - August 14th, 2026 [August 14th, 2026]
- Another Colorado Attack on the First Amendment Goes to the Supreme Court - Independence Institute - August 14th, 2026 [August 14th, 2026]
- Masked ICE Agent Pulls Gun on Virginia Driver Who Says She Was Exercising First Amendment Rights - National Enquirer - August 14th, 2026 [August 14th, 2026]
- Flag on the play: First Amendment problems with NIL regulation - FIRE | Foundation for Individual Rights and Expression - July 21st, 2026 [July 21st, 2026]
- Removal of CLARITY Acts Section 604 Could Spark First Amendment Battle, Industry Executives Warn - Cryptonews.net - July 21st, 2026 [July 21st, 2026]
- The Forever War and the First Amendment - | Knight First Amendment Institute - July 18th, 2026 [July 18th, 2026]
- Judge dismisses Chelan County deputies' claim that Morrison violated their First Amendment rights - The Wenatchee World - July 18th, 2026 [July 18th, 2026]
- INDIVIDUAL RIGHTS7th Cir.: Former Chicago firefighter cannot revive First Amendment claims involving racist Facebook posts - VitalLaw.com - July 18th, 2026 [July 18th, 2026]
- AI Chatbots Are at Risk of Spreading Government Restrictions on Online Speech, a New Study Says - First Amendment Watch - July 18th, 2026 [July 18th, 2026]
- Viral video at Pride protest prompts Fort Worth police to review First Amendment rights training - WFAA - July 16th, 2026 [July 16th, 2026]
- A New Jersey Judge Defies the First Amendment by Censoring News Coverage of a High School Lockdown - Yahoo - July 16th, 2026 [July 16th, 2026]
- 'They're Violating My First Amendment Right': A Video of a Man Being Removed From a Public Park During Arab Fest Is Dividing X - The Daily Dot - July 16th, 2026 [July 16th, 2026]
- DOJ weighs civil rights probe into Fort Worth police over alleged First Amendment violations - Fox News - July 16th, 2026 [July 16th, 2026]
- Human Rights Groups Sue Over Trump Administrations Sanctions on ICC for Investigations Into Israel - First Amendment Watch - July 16th, 2026 [July 16th, 2026]
- First Amendment Discussion with Journalists and Legal Experts Set for July 21 at National Press Club - PR Newswire - July 16th, 2026 [July 16th, 2026]
- When Speech or Association Undercuts the Mission: A First Amendment Guide for Law Enforcement Agencies - States United Democracy Center - July 16th, 2026 [July 16th, 2026]
- Elon professors join FCC filing on First Amendment, broadcast journalism - Elon University - July 16th, 2026 [July 16th, 2026]
- Letter to the Editor: SCC School Board must respect the First Amendment - baldwin-bulletin.com - July 16th, 2026 [July 16th, 2026]
- Subpoenas Issued to NY Times Reporters Seen as Unprecedented Threat To Press Freedom - First Amendment Watch - July 16th, 2026 [July 16th, 2026]
- Florida Government Weekly Roundup: Crossing The First Amendment - NorthEscambia.com - July 16th, 2026 [July 16th, 2026]
- David Schwartz invokes First Amendment to defend XRP sports ads - Cryptonews.net - July 16th, 2026 [July 16th, 2026]
- First Amendment Protects Universities From Florida's Stop WOKE Act - Reason Magazine - July 16th, 2026 [July 16th, 2026]
- Warwick tries to bar critic from disclosing information obtained in First Amendment suit - The Boston Globe - July 9th, 2026 [July 9th, 2026]
- South Milwaukee Orders Residents to Take Down Whimsical Skeleton Display, a Violation of Their First Amendment Rights - The Institute for Justice - July 9th, 2026 [July 9th, 2026]
- ABC Fights Back Against FCC Regulators in Dispute Over The View and Equal Time Rules - First Amendment Watch - July 9th, 2026 [July 9th, 2026]
- How does the First Amendment apply to AI regulation in hiring and health care? - FIRE | Foundation for Individual Rights and Expression - July 9th, 2026 [July 9th, 2026]
- Judge Orders E. Jean Carroll Be Paid $5.8M in Trump Sex Abuse and Defamation Case; Trump Appeals - First Amendment Watch - July 9th, 2026 [July 9th, 2026]
- First Amendment wins at Supreme Court to the horror of liberal justices - Washington Examiner - July 9th, 2026 [July 9th, 2026]
- Florida Tried to Stop Woke. The First Amendment Stopped Florida. - Cloaking Inequity - July 9th, 2026 [July 9th, 2026]
- ABC fires back at FCC investigation of 'The View' in new comments calling it a First Amendment violation - Fox News - July 9th, 2026 [July 9th, 2026]
- The Equal Rights Amendment and the First Amendment: A Roadmap for a Feminist Future - Ms. Magazine - July 1st, 2026 [July 1st, 2026]
- Expressive Governance Is a First Amendment Threat Hiding in Plain Sight - Tech Policy Press - July 1st, 2026 [July 1st, 2026]
- Supreme Court Strikes Down Limits on Party Spending in Federal Elections, Backing Republican Appeal - First Amendment Watch - July 1st, 2026 [July 1st, 2026]
- Another New York Resident Says He Was Warned by Officers After Criticizing ICE - First Amendment Watch - July 1st, 2026 [July 1st, 2026]
- Gateway Church wins tithing lawsuit dismissal as federal judge cites First Amendment - The Roys Report - June 28th, 2026 [June 28th, 2026]
- ACLU raises First Amendment concerns over Hartland library boards decision to reshelve LGBTQ+ books - News From The States - June 28th, 2026 [June 28th, 2026]
- Weakening Government Coercion by Strengthening Government Regulation - | Knight First Amendment Institute - June 28th, 2026 [June 28th, 2026]
- Former Executive Sues Meta Over Attempts To Silence Her Memoir, Careless People - First Amendment Watch - June 28th, 2026 [June 28th, 2026]
- ACLU raises First Amendment concerns over Hartland library boards decision to reshelve LGBTQ+ books - Iosco County News Herald - June 28th, 2026 [June 28th, 2026]
- New York City Council Candidate Is Accused of Forgery Over AI-Generated Posts - First Amendment Watch - June 28th, 2026 [June 28th, 2026]
- Why the Prairieland case is more about disproportionate justice than it is the First Amendment - Media Nation - June 28th, 2026 [June 28th, 2026]
- Reflecting on Americas 250th anniversary: The First Amendment - Princeton University Press - June 24th, 2026 [June 24th, 2026]