People v. Wood, 127 N.E.3d 1

In March 2013 Alexander Wood left an angry, profanity-filled voicemail at the public defender’s office saying he "dreamed about revenge" and that he "prayed for the death and destruction upon the judge," specifically naming Judge Anthony Calabrese.
The voicemail was played for Judge Calabrese by an assistant public defender; the judge felt threatened, changed his routine, and alerted court security.
Wood was later identified as the caller, arrested, convicted by a jury of threatening a public official, and sentenced to two years in prison.
Wood admitted making the call but testified he intended the message for the public defender, not the judge, and did not intend it as a threat—he claimed it expressed frustration and hopes, not an intent to act.
The State relied on context (blocked number, after-hours call, naming the judge, Wood’s prior phone-threat conviction) to argue the message was a true threat and that it was indirectly conveyed to the judge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the voicemail constituted a "true threat"	The content and context (naming judge, prior threats, timing) show a threatening communication that would place the judge in reasonable apprehension	The message expressed hyperbolic hopes and hatred but contained no serious expression of intent to commit unlawful violence	Not a true threat as a matter of law; statements were aspirational/hyperbolic and lacked expression of intent to act
Whether defendant knowingly communicated the threat to the judge (directly or indirectly)	It was practically certain the public defender’s office would relay such a message to the judge, so the threat was indirectly conveyed	Wood intended the message for the public defender and there was no evidence he intended it to reach the judge; public defenders are not law enforcement and he could have called chambers	Reversed: State failed to prove Wood knowingly transmitted the communication to the judge; no evidence he intended judge to hear it

Virginia v. Black, 538 U.S. 343 (2003) (defines a "true threat" as a serious expression of intent to commit unlawful violence)
Elonis v. United States, 135 S. Ct. 2001 (2015) (requiring proof of the defendant's intent that the communication be threatening and that a reasonable listener would understand it as such)
Watts v. United States, 394 U.S. 705 (1969) (context is important in assessing threats)
People v. Peterson, 306 Ill. App. 3d 1091 (1999) (letters containing clear demands and specified consequences held to be threatening/intimidation)
Mahaffey ex rel. Mahaffey v. Aldrich, 236 F. Supp. 2d 779 (E.D. Mich. 2002) (listing names under "people I wish would die" held not to be an actual threat)
Bauer v. Sampson, 261 F.3d 775 (9th Cir. 2001) (fantasies and illustrative writings of revenge are not true threats)