Definition of ''true Threat'' in New York

In People v. Orr (47 Misc 3d 1213[A], 15 N.Y.S.3d 713, 2015 NY Slip Op 50568[U]) the court determined that New York courts have consistently found that there is no "true threat" in those cases where the communication either did not contain a threat of future violence at all or the seeming threat was not sufficiently specific. The Orr court found that there is a "true threat" where "the communication conveyed a clear and unambiguous message that the recipient could not help but understand as a threat of future injury" (id.).