Paul misunderstands two things:

1. Due Process required for incarcerated pro se defendants, and

2. Counterman v. Colorado, 600 U.S. 66, 66, 143 S. Ct. 2106, 2109 (2023), deals with mens rea (criminal intent) not actus reus (bad acts).

The State v. Billings, 217 Conn. App. 1, 287 A.3d 146 (2022) case he cites is nice, but it deals with actus reus can be overturned by the Connecticut Supreme Court on a "contract" to protect the Connecticut judiciary. It is clear that both conduct and unprotected speech can form basis for harassment conviction.

After Counterman, the State of Connecticut must prove in true-threats cases that the defendant had some understanding of his statements’ threatening character. A recklessness standard is enough. This the State Attorney has not done before the grand jury. This they have not done pre-trial. This they cannot do at trial.

If Boyne gets on this horse, he can ride it to victory.