Whether the government must prove a defendant knowingly intends his communications to be a threat

QUESTION PRESENTED FOR REVIEW Whether, in light of this Court’s holding in Elonis v. United States, 135 S. Ct. 2001 (2015), that, to obtain a conviction under 18 U.S.C. § 875(c), the government must prove that a defendant knowingly intends his communications to be a threat, can it be harmless error if the defendant’s subjective mental state was never an element presented to a grand jury or pled by the government in an indictment? i INTERESTED PARTIES There are no