Rendelman v. United States

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS SCOTT L. RENDELMAN, ) Petitioner, } vs. } Case No. 23-CV-3475-SMY UNITED STATES OF AMERICA, Respondent. MEMORANDUM AND ORDER YANDLE, District Judge: Scott Rendelman filed a motion under

28 U.S.C. § 2255

to vacate his convictions based on Counterman v. Colorado,

600 U.S. 66

(2023) (Doc. 1). Relying on the Supreme Court’s holding that the First Amendment requires a subjective understanding of a statement’s threatening nature in true-threat cases, he argues the jury instructions in his case were erroneous in that regard. The…