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U.S. v. Washington, No. 96-3092 (7th Cir.) (109 F.3d 335) (March 17, 1997) (Judge Frank H. Easterbrook)

In what is probably the first case to address the meaning of "threats" within the meaning of the Three Strikes Statute, the court held that term encompasses a communicated expression that the defendant would use a gun.

 

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