California, United States of America
The following excerpt is from People v. Ferea, H037332 (Cal. App. 2014):
To prove the crime of criminal threat, the prosecution must prove, among other things, that the threat caused the victim to be in sustained fear for his or her own safety or for his or her immediate family's safety and that the fear was reasonable under the circumstances. (Pen. Code, 422; People v. Toledo (2001) 26 Cal.4th 221, 228.)
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