In US v. Zavrel, the Third Circuit U.S. Court of Appeals heard an appeal by a woman convicted under 18 U.S.C. section 876, for sending a "communication containing any threat to injure the person of the addressee."

In October of 2001, "Rosemary Zavrel mailed seventeen envelopes containing a white powdery substance she intended to resemble anthrax to various local officials, school and hospital workers, and to the President of the United States."

Zavrel and her roommate planned to frame two boys who had supposedly wrongly accused Zavrel's son of making terroristic threats. The envelopes, which actually contained cornstarch, bore the return address of the son's accusers and were stamped with "Love USA" theme postage. Clever.

The Court ruled that "in the wake of the 2001 anthrax scare, mailing cornstarch does constitute a communication under 18 U.S.C. § 876," and that the phony anthrax envelopes constituted threats to injure the recipient within the meaning of the statute.

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