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CHARLES RANDALL FREEMAN v. STATE OF MARYLAND

Criminal law — Sufficiency of evidence — Threat of arson and mass violence

After leaving a voicemail message at a psychiatric hospital where he had been a patient, appellant Charles Randall Freeman was charged with one count of making a threat of arson in violation of Md. Code (2002, 2012 Repl. Vol., 2018 Cum. Supp.), § 6-107 of the Criminal Law Article (“Crim.”), and one count of making a threat of mass violence in violation of Crim. § 3-1001. In a bench trial, the Circuit Court for Dorchester County convicted Freeman on both counts. Freeman challenges those convictions, arguing that the evidence is insufficient to establish that he threatened to blow up a structure or harm more than five people and that his recorded message is protected by the First Amendment because it did not rise to the level of a “true threat.”

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