Nassau v. State, 311 Ga. App. 438

Nassau scheduled a property showing, found the power off and the meter removed, and suspected Snapping Shoals EMC had removed it.
Nassau spoke with a night dispatcher, was told he could pay to restore power that night, and grew angry after the explanation.
In a first call Nassau threatened that if any technicians came to his property it would go down, and he threatened violence if not resolved; a dispatcher warned this could be prosecuted as a terroristic act.
Nassau made a second call the next day, threatening violence toward technicians and stating he would shoot if they did not come to his door; CSR supervisor noted the threats for sheriff's report.
Nassau was indicted on two counts of making terroristic threats; a bench trial followed with testimony from the dispatcher and CSR and a digital recording of the calls introduced as evidence.
The trial court convicted Nassau on both counts; on appeal Nassau argues the evidence failed to prove threats directed at a specific victim beyond a reasonable doubt.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence shows threats were directed at a specific victim	Nassau's threats were general and not aimed at a particular person.	The threats were not directed to any single victim, so no terroristic threat not meet statute.	Yes, threats were to Snapping Shoals EMC employees; convictions affirmed.

Joiner v. State, 299 Ga.App. 300 (2009) (standard for sufficiency; weigh evidence limited; rationality test)
Jackson v. Virginia, 443 U.S. 307 (1979) (establishes rational juror standard for sufficiency)
Armour v. State, 265 Ga.App. 569 (2004) (threats must be directed to convey to victim; intent to terrorize)
Brown v. State, 298 Ga.App. 545 (2009) (upholds conviction when threats directed to victims; identifiable target)
Sidner v. State, 304 Ga.App. 373 (2010) (reverses when no evidence threats directed to any particular person)