speech." The categorical distinction is particularly difficult to apply to statutes that proscribe threats. Generally, threats involve words, or "speech.” Moreover, in the R.A.V. case itself, the Court implicitly suggested that threats did not fall within its exception for statutes "directed at conduct.” See R.A.V., — U.S. at --, 112 S.Ct. at 2546 (describing 18 U.S.C. § 871, which proscribes threats against the President, as fully subject to its general rule). Nonetheless, as I discuss below, at least one panel in this circuit has held that a civil rights statute selectively proscribing threats of force is “directed at conduct” and thus not subject to the R.A.V. general rule. Hayward, 6 F.3d at 1251 (42 U.S.C. § 3631, as applied to a cross-burning incident); cf. J.H.H., 22 F.3d at 826 (<HOLDING>); but cf. United States v. Lee, 6 F.3d 1297,
holding that interference with the right to service in a restaurant is chargeable under 18 usc  241 holding that a state is not a person under 42 usc  1983 holding that 18 usc  245 a statute passed on the same day as 42 usc  3631 and for similar purposes constituted a valid enactment under congress thirteenth amendment authority as applied to racially motivated interference with federallyprotected rights holding that 18 usc  1919 did not implicitly repeal 18 usc  1001 holding that 18 usc  241 and 42 usc  3631 fall within a separate exception to rav