What is the test for making a specific threat to the eviction personnel?

Defendants make much of the fact that there was no specific threat (e.g., a specific verbal or written threat by the occupant to act violently toward the eviction personnel). However, there need not be a specific threat to the plaintiff. In Wood v. Ostrander, 879 F.2d 583 (9th Cir. 1989), for example, police arrested an intoxicated driver and impounded his automobile, leaving a female passenger on the side of the road five miles away from her home on a cold night in a high-crime area without a jacket or money. The passenger accepted a ride from a stranger who drove her to a secluded area and raped her.

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