U.S. v. Thomas, No. 97-3456 (7th Cir.) (155 F.3d 833) (August 11, 1998) (Judge Richard D. Cudahy)
Departing from the rule in most other Circuits, the Seventh Circuit suggested that the content of the defendant's threats alone (as opposed to some overt act) are sufficient to support an enhancement under USSG § 2A6.1(b)(1).
Here the Court determined that the defendant's violent letters, including one in which he ...
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