9.61.160 does not proscribe a substantial amount of constitutionally protected speech. It is therefore not unconstitutionally overbroad. Affirmed. Morgan and Bridgewater, JJ., concur. 1 84 Wn. App 5. 2 Smith appears to argue that the jury should have been instructed not to convict him unless it found that he used “fighting words.” Smith, however, has not assigned error to the jury instructions. 3 The court reached this conclusion because it defined “threat” as used in RCW 9.61.160 as including a threat to injure property. Edwards, 84 Wn. App. at 12. This type of threat may be constitutionally protected. See Stephenson, 89 Wn. App. at 801-02 (finding that threats to harm another’s business, financial condition, or personal relationships are protected speech); Knowles, 91 Wn. App. at 374 (<HOLDING>). RCW 9.61.160, however, is clearly concerned
holding that threats standing alone  constitute past persecution in only a small category of cases and only when the threats are so menacing as to cause significant actual suffering or harm  holding that threats to inflict financial or personal harm are not true threats where no ones personal safety is threatened holding that expansion of the ada to encompass threats to self is untenable because the ada mentions only threats to others holding that the first amendment does not protect true threats against the president holding that threats to fire employees based on legitimate concerns about productivity do not constitute harassment because any threats made to these plaintiffs  were no greater than justified by their lack of sales