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United States v. White

United States Court of Appeals for the Seventh Circuit

698 F.3d 1005 (2012)

Relevant factsFree

William White (defendant), editor of a white-supremacist website, repeatedly posted messages praising and advocating violence against various minority groups and against the judge and jurors who convicted a fellow white supremacist. After one posting celebrated the murder of the trial judge's family, White later posted the identifying information of the Hale case's gay, Jewish jury foreman ("Juror A"), prompting harassing, but not threatening, emails from readers. White was charged with soliciting a violent federal crime; after the district court initially dismissed the charge as protected speech, the Seventh Circuit reversed and remanded for trial, where the jury convicted White, but the trial judge granted a post-verdict acquittal, finding the evidence did not strongly corroborate intent to solicit violence. The government appealed again.

IssueFree

Whether an element of criminal solicitation under 18 U.S.C. Section 373 is at least one act taken under circumstances that strongly corroborate the defendant's intent to solicit a violent crime.

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