United States v. Keith Gilbert (Gilbert 1, 1987; Gilbert II, 1989). In 1980, Keith Gilbert, an avowed white supremacist, sent racially derogatory and “threatening” correspondence to Susan Smith, a White woman who operated an adoption agency that was trying to place minority children.
After remand, Gilbert was convicted at trial. On appeal after trial, he contended that the evidence was insufficient to prove a threat of force, a required element of the criminal provision of the Fair Housing Act. Gilbert argued that no single piece of correspondence threatened Ms. Smith.