Tuesday, February 17, 2026

U.S. v. Brandenberg (9th Cir. - Feb. 17, 2026)

In affirming a five-year sentence for threatening to bomb a state courthouse, Judge McKeown's opinion today correctly notes that:

"Brandenburg’s threats arose in a climate of serious threats nationwide against courthouses and judges. In 2008, the San Diego federal courthouse—one of the targets of Brandenburg’s threats—was bombed. See United States v. Love, No. 10-cr-2418-MMM, 2013 WL 1660415, at *1 (S.D. Cal. Apr. 17, 2013). In 2020, District of New Jersey Judge Esther Salas’s son was murdered by a plaintiff who had appeared before her, grimly echoing the killing fifteen years earlier of Northern District of Illinois Judge Joan Lefkow’s mother and husband by a disgruntled litigant. Esther Salas, Federal Judges Are at Risk, N.Y. Times, Dec. 9, 2020, at A25."

To that grim list I might add the bombing murder of Judge Robert Vance, the perpetrator of which was executed in 2018.