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Alonas v. United States
In 2003, the Supreme Court held that truth threats encompass those statements where the speaker means to communicate a serious expression of an intent to commit an active unlawful violence. But once they got the case, they decided it on pretty narrow grounds basically saying that the federal threat offense requires a guilty mind as a necessary element. So, I think that's what gives rise to our problem here means to communicate, according to whom objective or subjective fine is appropriate.
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