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U.S. v. Fulmer, No. 96-1331 (1st Cir.) (108 F.3d 1486) (March 28, 1997) (Judge Juan R. Torruella)

Here the court rejected as untenable the "reasonable recipient standard" - I.e., whether an ordinary, reasonable recipient would interpret the statements as a threat - because in that case "a defendant may be convicted for making an ambiguous statement that the recipient might find threatening because of events not within …

 

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