Whether jury instructions based on Elonis v. United States (2015) sufficiently encompass the requirement of 'subjective intent to threaten,' as articulated by the Supreme Court in Counterman v. Colorado (2028), or if such instructions fall short of this standard

QUESTION PRESENTED Whether jury instructions based on Elonis v. United States (2015) sufficiently encompass the requirement of "subjective intent to threaten," as articulated by the Supreme Court in Counterman v. Colorado (2028), or if such instructions fall short of this standard. i