California, United States of America
The following excerpt is from People v. Villagran, E059844 (Cal. App. 2015):
Similarly, defendant insists the "whole purpose of the call" was to ascertain whether the police were looking for him, not to threaten. "To be sure, defendant offered explanations for some of the[] circumstances [surrounding the call], but the jurors did not have to believe them." (People v. Dowl (2013) 57 Cal.4th 1079, 1092.) The evidence we discussed ante gave the jury sound reasons to reject defendant's characterization of his own behavior and find he made a threat that was sufficiently unequivocal, unconditional, and immediate.
c. The victim was in sustained and reasonable fear because of the threat
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