United States v. Robert Stahlnecker

DISCUSSION

Stahlnecker’s convictions resulted from phone calls he made to congressional

offices in 2019, purportedly to complain about the government’s treatment of

veterans. Many of those calls were laced with threats and profanity.

A. 18 U.S.C. § 875(c): Conviction on Count Three

Stahlnecker asserts three overlapping arguments as to why his conviction

under 18 U.S.C. § 875(c) (for threatening to injure an individual through an interstate

communication) should be overturned. None of the asserted challenges merit

reversal.

First, Stahlnecker argues that his § 875 conviction is not supported by

sufficient evidence. In reviewing the sufficiency of the evidence, we must determine

whether “after viewing the evidence in the light most favorable to the prosecution,

any rational trier of fact could have found the essential elements of the crime beyond

a reasonable doubt.” United States v. Nevils, 598 F.3d 1158, 1163–64 (9th Cir. 2010)

(en banc) (quoting Jackson v. Virginia, 443 U.S. 307, 319 (1979)). Here,

congressional intern Leah Uhrig testified that Stahlnecker told her “I am going to

fucking come to your office and kill you, you miserable little…