Richard Parker. "Parker v. Levy (1974)". The First Amendment Encyclopedia. Free Speech Center at Middle Tennessee State University. Retrieved 2020-04-01.
United States v. Glover, 846 F2d 339 (CA6 Ky 1988) ("We believe the threats made in the letters sent to the President were of a nature that a reasonable person would foresee that the receiver of the letters would perceive them to be a serious intention to inflict bodily harm upon or take the life of the President. If the appellant's argument were accepted, no prisoner could be convicted under this statute, since his argument seems to be premised on the idea that prisoners are incapable of carrying out threats, therefore, no reasonable person could consider such a threat to be a true threat. This premise is faulty. See United States v. Leaverton, 835 F.2d 254 (10th Cir. 1987) (inmates convicted for sending simulated mail bomb to Senator Robert Dole).").
