The Rev. Edward Pinkney was convicted in 2007 of paying people $5 to vote in a recall election in the southwestern Michigan city of Benton Harbor and was sentenced to probation.

Months later, Pinkney wrote a commentary in a Chicago-based populist newspaper that said Judge Alfred Butzbaugh could be punished by God with curses, fever and "extreme burning" unless he repented, a reference to an Old Testament passage. The black minister also described Butzbaugh, a white judge who presided over his case, as dumb, racist and corrupt.

In June 2008, another Berrien County judge sent Pinkney to prison for three to 10 years for violating probation with his words. Pinkney appealed saying his free-speech rights were trampled.