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.