State v. McWilliams, 2012 Ohio 663

Defendant McWilliams was charged with two counts of aggravated menacing arising from threats made at Ernie's Bar: one to bartender Hewitt and one to Mayor Cicchinelli.
The bar incident prompted Hewitt to record the license plate and police to issue a nationwide bulletin for officer safety.
McWilliams was found not guilty as to the Hewitt count and not guilty by reason of insanity as to the Mayor count; he was ordered treatment and prohibited from weapons possession and contact with Hewitt or the Mayor.
Appellant appealed the not guilty by insanity acquittal on the Mayor charge, challenging the trial court's handling and the legal standard for aggravated menacing.
The appellate court concluded the verdicts and proceedings were proper and addressed the proper interpretation of R.C. 2903.21 regarding whether a threat must be directed to the actual victim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the threat must be made directly to the victim	McWilliams argues threats must be direct to the victim.	State argues threats to a third party can suffice if conveyed to the victim.	Threats may be conveyed to a third party; direct delivery not required.

State v. Richard, 129 Ohio App.3d 556 (1998) (threats need not be made directly to the victim; focus on statute language)
State v. Knoble, 2008-Ohio-5004 (9th Dist. 2008) (conviction sustained when threat conveyed to persons who would convey to victim)