The DC Court of Appeals in Lee Carroll v. U.S., decided on August 3rd, 2017; redefined the legal requisite for criminal conviction under the Threats’ Statute. Factually, the defendant was convicted for assaulting his girlfriend while also verbally threatening her physical harm. The DC misdemeanor as well as the Felony threats statutes do not enlist legal elements nor require facially mens rea or criminal intent. The misdemeanor threats statute (D.C. Code § 22-407) provides: Whoever is convicted in the District of threats to do bodily harm shall be fined not more than the amount set forth in § 22-3571.01 or
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