The Third Circuit Court of Appeals affirmed a district court's restitution order against Kyle Stevens, who pleaded guilty to federal cyberstalking and interstate threat charges stemming from a campaign of online harassment against a former University of Delaware classmate.

In a non-precedential opinion filed Jan. 16, a three-judge panel rejected Stevens's appeal challenging specific components of the restitution award. Stevens had objected to the inclusion of costs the victim incurred following his arrest and expenses related to the victim's out-of-state car registration.

The case traces back to Stevens's time as a University of Delaware student during the 2018-2019 academic year, when he first met the victim. In 2019, Stevens pleaded guilty to harassing the victim and received a probation sentence. After completing his probation, Stevens relocated to Germany.

From his overseas location, Stevens launched a sustained campaign of digital harassment against his former classmate. Between September 2021 and November 2021, Stevens sent numerous threatening messages through various online platforms. The threats were graphic and violent in nature, with Stevens writing messages such as "I'm going to slaughter you. I'm going to string you up. I'm going to put you on hooks in the back of a freezer like a fucking cow," and threatening to put a "bullet in your head."

The interstate nature of Stevens's conduct - sending threats from Germany to a victim in the United States - brought the case under federal jurisdiction for cyberstalking and interstate threat charges. Stevens ultimately pleaded guilty to these federal charges in the U.S. District Court for the District of Delaware, presided over by Judge Richard G. Andrews.

As part of the sentencing process, the district court ordered Stevens to pay restitution to compensate his victim for various costs and expenses related to the harassment campaign. However, Stevens contested certain aspects of the restitution calculation, specifically objecting to two categories of expenses.

First, Stevens challenged the inclusion of costs the victim incurred following Stevens's arrest. The nature of these post-arrest expenses was not detailed in the available court documents, but Stevens argued they should not be included in his restitution obligation.

Second, Stevens objected to the inclusion of costs related to the victim's out-of-state car registration. Again, while the specific circumstances surrounding these registration costs were not elaborated upon in the court filings, Stevens maintained they were not properly attributable to his criminal conduct.

The District Court for the District of Delaware rejected both of Stevens's objections to the restitution order. Judge Andrews determined that both categories of expenses were appropriately included in the restitution calculation.

Stevens subsequently appealed the restitution ruling to the Third Circuit Court of Appeals. The case was heard by Circuit Judges Patty Shwartz, Cindy Chung, and Thomas Ambro. The appeal was submitted under Third Circuit Local Appellate Rule 34.1(a), which governs cases deemed suitable for disposition without oral argument.

In their per curiam opinion, the three-judge panel affirmed the district court's restitution order in its entirety. The appellate court found that the District Court had "correctly overruled" Stevens's objections to the inclusion of the contested expenses.

The Third Circuit's opinion was designated as "not precedential," meaning it does not establish binding legal precedent for future cases. Such non-precedential opinions are common in federal appellate courts for cases that do not present novel legal issues or require extensive legal analysis.

The ruling represents the conclusion of Stevens's challenge to the restitution order, though the specific dollar amount of the restitution was not disclosed in the available court documents. Federal restitution orders are designed to compensate victims for the direct and proximate consequences of criminal conduct, including both economic losses and expenses incurred as a result of the offense.

Cyberstalking cases have become increasingly common as digital communication platforms proliferate and criminals exploit technology to harass and threaten victims across state and international boundaries. Federal jurisdiction in such cases typically arises when the conduct crosses state lines or involves interstate commerce, as occurred in Stevens's case with his Germany-to-United States communications.

The case highlights the serious legal consequences that can result from online harassment campaigns, particularly when they involve explicit threats of violence. Stevens's progression from a 2019 state harassment conviction to federal cyberstalking charges demonstrates how escalating patterns of harassment can lead to increasingly severe legal penalties.

With the Third Circuit's affirmation of the restitution order, Stevens's legal challenges to his sentence appear to be exhausted, barring any potential petition to the Supreme Court, which would face significant hurdles given the case's non-precedential status and fact-specific nature.