RAWLINSON, Circuit Judge.
Jonathan Joseph Lincoln (Lincoln) was convicted of knowingly and willfully threatening the life of the President of the United States in violation of 18 U.S.C. § 871. The charge arose from statements made in a letter dated September 24, 2001 that Lincoln attempted to mail while incarcerated at the Oregon State Penitentiary. The district court acknowledged that the letter itself was not a "true threat," but determined that a true threat...
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