In In re Doe, 76 Hawai'i 85, 869 P.2d 1304 (1994) the Hawai'i Supreme Court reasoned that when the offense of harassment is committed against a police officer, the risk of provoking a response from the officer is considered against "the officer's training and professional standard of restrained behavior." Id., at 96, 869 P.2d at 1315. Essentially, the Hawai'i Supreme Court has raised the threshold when the victim of the harassment or the threat is a police officer.