182374P.pdf   10/21/2020  United States  v.  Joseph Dierks
   U.S. Court of Appeals Case No:  18-2374
   U.S. District Court for the Northern District of Iowa - Waterloo   
   [PUBLISHED] [Kobes, Author, with Loken and Colloton, Circuit Judges] 
   Criminal case - Criminal law. The evidence was sufficient to support 
   defendant's conviction for transmitting a threatening communication in 
   interstate commerce in violation of 18 U.S.C. Sec. 875(c); while the 
   instructions should have required both a subjective finding of knowledge 
   or intent and also an objective finding that the communication was 
   threatening, the error was harmless because the tweets in issue were 
   objectively threatening and it is clear beyond a reasonable doubt that a 
   rational jury would have found defendant guilty absent the error; no error 
   in permitting testimony from a law enforcement officer about the meaning 
   of the internet slang used in the tweets; no error in refusing to admit 
   what defendant claimed was an exculpatory tweet he sent 18 hours after the 
   tweets in question as it was not contemporaneous enough with the charged 
   tweets.