Fourth Circuit Announces Counterman v. Colorado Is New Rule of Constitutional Law That Applies Retroactively to Cases on Collateral Review and Grants Authorization to File Successive § 2255 Motion by Douglas Ankney The United States Court of Appeals for the Fourth Circuit granted Scott Lewis Rendelman’s motion for authorization to …

Massachusetts Supreme Court Vacates Threat-Based Conviction on First Amendment Grounds Because Jury Instructions Failed to Include Mens Rea Element Mandated by Counterman for ‘True-Threat’ Conviction by Sam Rutherford by Sam Rutherford The Supreme Judicial Court of Massachusetts vacated a threat-based conviction because the jury instructions provided setting forth the elements …