Doe v. Pulaski County Special School District

In Doe v. Pulaski County Special School District, 306 F.3d 616 (8th Cir. 2002), the Eighth Circuit listed five non-exhaustive factors relevant to the issue of how a reasonable person would receive an alleged threat. 306 F.3d at 623. One of those factors was whether the person who made the alleged threat communicated it directly to the object of the threat. Id. The Eighth Circuit also considered the reactions of those who heard the threat, whether the threat was conditional, whether the speaker had a history of making threats against the object of the threat, and whether the object of the threat had reason to believe that the speaker had a violent tendency. Id.