United States v. Havelock

FISHER, Circuit Judge,

with whom

JOHNNIE B. RAWLINSON, Circuit Judge, joins, dissenting:

I respectfully dissent. Although I agree with the majority that we may look to the contents of a communication to determine to whom it is addressed, I disagree with the majority that Havelock’s communications were not “addressed to any other person.” 18 U.S.C. § 876(c).

As an initial matter, I have some doubts regarding the majority’s conclusion that § 876(c) applies only to communications addressed to natural persons. Although there is some reason to reach that conclusion, the context in which the phrase…