context: Section 18-8-806 has been construed as criminalizing certain threats as viewed from an objective, reasonable person's perspective. After Watts, and prior to Black, courts construing other criminal statutes proscribing certain types of threats almost uniformly applied an objective standard (from either the speaker's or the recipient's perspective) to determine whether a statement was a true threat.
citation_a.signal: see
citation_a.identifier: 973 P.2d 1225, 1231, 1233
citation_a.parenthetical: threat cognizable under SS 18-9-111, criminalizing harassment by stalking, assessed under "an objective 'reasonable person' standard"
citation_a.sentence: See, e.g., People v. Baer, 973 P.2d 1225, 1231, 1233 (Colo.1999) (threat cognizable under § 18-9-111, criminalizing harassment by stalking, assessed under "an objective 'reasonable person' standard"); United States v. Fulmer, 108 F.3d 1486, 1490-91 (1st Cir.1997); United States v. Aman, 31 F.3d 550, 553-56 (7th Cir.1994); United States v. Malik, 16 F.3d 45, 49 (2d Cir.1994); United States v. Kosma, 951 F.2d 549, 556-57 (3d Cir.1991); United States v. Orozco-Santillan, 903 F.2d 1262, 1265 (9th Cir.1990).
citation_b.signal: but see
citation_b.identifier: 438 F.2d 13, 15
citation_b.parenthetical: in prosecution for threatening the President, the prosecution must prove a present intent to do injury if the threat is communicated to someone other than the President
citation_b.sentence: But see United States v. Patillo, 438 F.2d 13, 15 (4th Cir.1971) (en banc) (in prosecution for threatening the President, the prosecution must prove a present intent to do injury if the threat is communicated to someone other than the President).