The U.S. Court of Appeals for the Seventh Circuit affirmed the conviction of Farhan Sheikh, who threatened to kill doctors, patients, and visitors at a Chicago abortion clinic through a social media post in 2019. The decision, issued Jan. 13, rejected Sheikh's constitutional challenges to federal threat laws and his claims of procedural errors during trial.
Sheikh was convicted under 18 U.S.C. § 875(c), which criminalizes interstate transmission of threatening communications. The case arose from a post he made on the social media platform iFunny in August 2019, while he was a college student working part-time.
On Aug. 13, 2019, Sheikh posted a message on his public iFunny account targeting the Women's Aid Center in Chicago. In the post, he wrote that he was "done with my state and thier bullshit abortion laws" and threatened to "slaughter and murder any doctor, patient, or visitor i see in the area" on a specific date. The post included explicit threats against anyone visiting the clinic and contained a warning to potential victims.
The case highlights the intersection of social media communications, abortion clinic safety, and federal threat prosecution. Sheikh's iFunny account was public, meaning anyone could view his posts. The platform was known for users sharing humorous content, including dark humor about serious subjects, though Sheikh typically posted non-humorous content such as soccer photographs and videos.
During the appeal process, Sheikh mounted several legal challenges to his conviction. He argued that Section 875(c) itself was unconstitutional, challenged whether the grand jury that indicted him was adequately informed about applicable law, and claimed that improper evidence was admitted during his trial.
The Seventh Circuit panel, consisting of Circuit Judges Ripple, Kirsch, and Lee, rejected all of Sheikh's arguments. Circuit Judge Kirsch wrote the opinion affirming the conviction, stating that Sheikh's challenges "fail to persuade."
The constitutional challenge centered on the scope and application of federal threat statutes. Section 875(c) has been the subject of ongoing legal debate regarding its application to social media communications and the standards required to prove a "true threat" versus protected speech under the First Amendment.
Sheikh's case was prosecuted in the U.S. District Court for the Northern District of Illinois, Eastern Division, where Judge Mary M. Rowland presided. The case was designated as No. 19 CR 655, indicating it was filed as a criminal case in 2019.
The conviction comes amid heightened concerns about security at abortion clinics nationwide. Federal law enforcement agencies have increased focus on threats against healthcare facilities and personnel, particularly those providing reproductive health services. The case demonstrates how social media platforms can be used to transmit threatening communications that fall under federal jurisdiction when they cross state lines.
The timing of Sheikh's post was particularly concerning to authorities, as he specified a date and location for carrying out the threatened violence. This specificity likely strengthened the prosecution's case that the communication constituted a genuine threat rather than hyperbolic or protected speech.
Federal threat prosecutions often hinge on whether communications constitute "true threats" that are not protected by the First Amendment. Courts examine factors including the context of the communication, the reaction of recipients, and whether a reasonable person would interpret the statement as a serious expression of intent to commit violence.
The iFunny platform's culture of dark humor may have influenced Sheikh's defense strategy, though the appeals court found his arguments unpersuasive. The case illustrates the challenges courts face in distinguishing between protected speech, even offensive speech, and criminal threats in the digital age.
Oral arguments in the appeal were heard Nov. 5, 2025, with the decision issued approximately two months later. The relatively quick turnaround suggests the panel found Sheikh's arguments straightforward to address based on existing precedent.
The affirmation of Sheikh's conviction reinforces federal authority to prosecute threats made via social media platforms, regardless of the platform's general culture or the defendant's typical posting behavior. It also demonstrates that college student status does not provide immunity from prosecution for threatening communications.
For abortion clinic security, the case represents successful prosecution of online threats that could intimidate patients and staff. The specific targeting of a named facility and detailed threats against various categories of people at the clinic likely made this a priority case for federal prosecutors.
The decision leaves Sheikh's conviction intact, though he may seek further review through a petition for rehearing or potentially an appeal to the Supreme Court. Given the panel's unanimous rejection of his arguments and the routine nature of affirming threat convictions under established precedent, further appellate review appears unlikely to succeed.