United States v. Loren Francis Bellrichard

994 F.2d 1318, 1993 U.S. App. LEXIS 13209, 1993 WL 188255
CourtCourt of Appeals for the Eighth Circuit
DecidedJune 7, 1993
Docket92-2911
StatusPublished
Cited by85 cases

This text of 994 F.2d 1318 (United States v. Loren Francis Bellrichard) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eighth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Loren Francis Bellrichard, 994 F.2d 1318, 1993 U.S. App. LEXIS 13209, 1993 WL 188255 (8th Cir. 1993).

Opinion

BOWMAN, Circuit Judge.

Loren Bellrichard appeals from his conviction on each of four counts of sending threatening communications through the mail in violation of 18 U.S.C. § 876 (1988). 1 Bell-richard was charged with two counts of bombing a building used in interstate commerce and twenty-three counts of sending threatening communications through the mail. Prior to trial, the District Court 2 granted the government’s motion to dismiss nine of the threatening-communications counts. The jury found Bellrichard not guilty of the two bombing counts 3 and guilty of five of the remaining fourteen threatening-communications counts. The court granted Bellrichard’s motion for judgment of acquittal on one of these five counts and denied the motion as to the remaining four counts. Bellrichard was sentenced to a term of imprisonment of fifty months, supervised re *1320 lease for three years, and a special assessment of $200.00.

The correspondence involved in the four counts of conviction falls into a pattern. Bellrichard has an extensive history of writing to people who are involved in issues that he is interested in, whether or not Bellrich-ard is personally involved. He took an interest in a heavily publicized case involving the prosecution of some juveniles as adults, and he sent a postcard to Nancy Evans, the county attorney. 4 Bellrichard also took an interest in the proposed building of a garbage incinerator, and mailed a postcard to Lee Leubbe, who was on the County Board of Commissioners. 5 Bellrichard was charged with harassment in connection with a movie theatre incident, and he wrote a letter to the county attorney involved in prosecuting the charges and to the police officers involved in the incident. 6 Finally, Bellrichard sent a *1321 postcard to Judge Michael Seibel, who had issued a search warrant for the homes of Bellrichard and his mother in connection with the bombing incidents for which Bell-richard later was charged. 7

Bellrichard does not deny that he wrote and mailed the postcards and letter. His only contention is that his convictions must be reversed as violative of his First Amendment right to freedom of speech because none of the language in his correspondence constituted a “true threat.” Bellrichard likens his case to that of the eighteen-year-old youth in Watts v. United States, 394 U.S. 705, 89 S.Ct. 1399, 22 L.Ed.2d 664 (1969), who had just received his draft card and at a rally in Washington, D.C. said, “If they ever make me carry a rifle the first man I want to get in my sights is L.B.J.,” to which remark the crowd laughed. Id. at 706, 707, 89 S.Ct. at 1401, 1401. He was convicted under 18 U.S.C. § 871 for threatening the life of the President (§ 871 uses language substantially similar to that of § 876, but is limited to threats aimed at the President). The Supreme Court reversed Watts’s conviction, agreeing with his argument that his remark was not a threat but only “a kind of very crude offensive method of stating a political opposition to the President.” Watts, 394 U.S. at 708, 89 S.Ct. at 1402. The Court concluded that “[tjaken in context, and regarding the expressly conditional nature of the statement and the reaction of the listeners, we do not see how it could be interpreted otherwise.” Id.

We find significant differences between Watts and the present case, and we have no difficulty in finding that Bellrichard’s correspondence does not fall within the protection of the First Amendment. In Chaplinsky v. New Hampshire, 315 U.S. 568, 571-72, 62 S.Ct. 766, 768-69, 86 L.Ed. 1031 (1942), the Supreme Court made it clear that speech may be regulated if it does not in any sense contribute to the values of persuasion, dialogue, and the free exchange of ideas that the First Amendment was designed to advance. When determining whether an alleged threat falls outside the realm of protected speech, it is important to focus on the context of the expression. Watts, 394 U.S. at 708, 89 S.Ct. at 1402; see also Martin v. United States, 691 F.2d 1235, 1240 (8th Cir.1982), cert. denied, 459 U.S. 1211, 103 S.Ct. 1207, 75 L.Ed.2d 447 (1983).

Initially, we note that all Bellrichard’s correspondence at issue here was sent to the recipients’ home or work addresses. As a general proposition, correspondence of this sort delivered to a person at home or at work is somewhat more likely to be taken by the recipient as a threat than is an oral statement made at a public gathering, which was the situation in Watts. Although the govern *1322 ment agreed to save time at trial by not presenting evidence of the recipients’ reactions to the letters, we suspect that, unlike the crowd at the anti-war rally in Watts, the recipients did not laugh when they read Bell-richard’s messages.

It is necessary, of course, for us to review each piece of correspondence that Bellrichard was convicted for sending. Although Bellrichard’s postcard to Nancy Evans contained his opinion about the public issue of whether certain juvenile defendants should be sentenced as adults, a person may not escape prosecution for uttering threatening language merely by combining the threatening language with issues of public concern. See United States v. Lincoln, 589 F.2d 379, 382 (8th Cir.1979) (per curiam) (defendant’s letter contained criticism of the judicial process, but it was an issue of fact for the jury to decide whether letter was threatening, and defendant’s conviction did not violate the First Amendment). There are several parts of Bellrichard’s postcard to Nancy Evans that a jury reasonably could view as a “true threat” and thus outside First Amendment protection. He wrote that if the two juveniles in question were sentenced to an adult prison “you will die,” and “[i]f they go to prison you’ll be dead in less than 7 months — -so help me God!” A threat may be considered a “true threat” even if it is premised on a contingency. See United States v. Howell, 719 F.2d 1258, 1260-61 (5th Cir.1983) (hospital patient’s statement that he would kill the President if released was a true threat), cert. denied, 467 U.S. 1228, 104 S.Ct. 2683, 81 L.Ed.2d 878 (1984). Bellrichard’s conviction for sending the postcard to Nancy Evans does not violate the First Amendment.

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Bluebook (online)
994 F.2d 1318, 1993 U.S. App. LEXIS 13209, 1993 WL 188255, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-loren-francis-bellrichard-ca8-1993.