adopt today. Congress has often explicitly included a required mental state in other hoax statutes. See, e.g., 18 U.S.C. § 35(b) (requiring that a false bomb threat on an airplane be made “willfully and maliciously, or with reckless disregard for the safety of human life”); 18 U.S.C. § 844(e) (requiring that a hoax about a “fire or an explosive” be made “willfully” or “maliciously”). Instead of including these specific terms of art in § 1038(a), Congress crafted this statute using the language “under circumstances where” and “may reasonably be believed.” 18 U.S.C. § 1038(a)(1). This is a noticeable difference, and we have read statutes with language similar to § 1038(a)(1) as containing an objective reasonableness standard. See Roy v. United States, 416 F.2d 874, 877-78 (9th Cir.1969) (<HOLDING>); see also United States v. Hanna, 293 F.3d
holding that the statement i have a gun is a threat of death holding that the crime of knowingly and willfully threatening the president required only that the threat be made under circumstances where a reasonable person would foresee that the statement would be interpreted by those to whom it is addressed as a serious threat and not be the result of mistake duress or coercion holding that speech must be a threat or coercion to be actionable holding that a threat to harm another person is a crime of violence holding that duress or coercion would invalidate a contract if the coercion comes from the opposing party not the claimants attorney