Newly filed court records allege that the man accused of opening fire on a Colorado movie theater in July told a classmate he wanted to kill people four months before the shooting.
Prosecutors wrote that Holmes left the program in June after also making unspecified threats to a professor that month and failing his year-end final.
Holmes' attorneys argue that prosecutors should have no access to his student records. The papers they filed in response to prosecutors do not address the allegations of threats.
Holmes' defense lawyer, Daniel King, has said Holmes is mentally ill, setting up a possible insanity defense.
But arguments at a hearing Thursday by Chief Deputy District Attorney Karen Pearson revealed a possible motive: Holmes' anger that he was failing at school, "at the same time he's buying an enormous amount of ammunition, body armor and explosives."
A gag order has been issued in the case. Prosecutors argued that gaining access to the school records would establish a motive by showing what Holmes hoped to accomplish at Colorado University and the "dissatisfaction with what occurred in his life that led to this."
They also want to see records from campus police and a campus threat evaluation team similar to those established across the country after the 2007 Virginia Tech University shootings.
Copyright 2012 The Associated Press.