Fourth Circuit: US v. William White

Crim - Extortion

Lack of subjective 'true threat' instruction ultimately harmless error.

Claim of right to the funds owed does not bar prosecution for communicating threats of physical harm, as the threats are themselves wrongful.

As the jury was told that it was being empaneled anonymously to prevent press communication, no error in anonymous empanelment.

Telephone notes admitted on direct as present-sense impressions might have been hearsay, but harmless error.

Sentence did not inappropriately consider deft's political views.

No error in not grouping counts.

http://www.ca4.uscourts.gov/Opinions/Published/144375.P.pdf