Suggs v. State

A jury convicted the defendant of four counts of “written threat to kill or do bodily injury” for sending two letters, each of which threatened the same two persons. *147The defendant argues that his convictions violate the double jeopardy clause.1 More specifically, he argues that the “allowable unit of prosecution” for the charge should be the number of letters or communications sent, and not the number of people to whom each letter or communication is sent.2 We disagree. We hold that the allowable unit of prosecution is the number of persons to whom each letter or communication is sent, and…