Case Involving Threat to Kill a Social Worker
In Davis v. State, 890 S.W.2d 489 (Tex.App. - Eastland 1994, no pet'n), the court found that the defendant threatened to kill a social worker for Child Protective Services who was considering the termination of the defendant's parental rights.
In Davis, the defendant stated that he had a criminal mind, that he was "tired of all you people...messing with me," and that he was thinking like George Lott did when he "killed all those people." Id. at 491.
The court stated in a footnote that George Lott shot and killed two people and wounded three others in the courtroom of the Fort Worth Court of Appeals on July 1, 1992. Id. at n.1.
The court held that, in order to support a conviction for retaliation, a threat need not be direct. Id.