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AO 72A (Rev. 8/82) Sullivan, 376 U.S. 254, 270 (1964)). Moreover, Anglo-American jurisprudence in recent centuries has rejected the notion that a person’s mere thoughts, however evil, can be criminalized. See id. at 709-711 & nn.1, 2 (Douglas, J., concurring) (discussing English law of constructive treason and the American Alien and Sedition Acts); United States v. Alkhabaz, 104 F.3d 1492, 1494 (6th Cir. 1997) (“our law does not punish bad purpose standing alone”). Thus, in Watts, the Supreme Court reversed the defendant’s conviction under 18 U.S.C. § 871 for threatening the life of President Johnson under circumstances clearly indicating that his remarks were nothing more than “a kind of very crude offensive method of stating a political opposition to the President.”? 394 U.S. at 708. On the other hand, true threats enjoy no legal protection. See United States v. Kosma, 951 F.2d 549, 553 (3d Cir. 1991). At the polar opposites, this distinction is easily applied. Had Fenton accosted Congressman Murtha in person or written him a letter, there would be no question, based on the words he used, that a true threat was intended. The remarks need only be such that “a reasonable person would foresee that the statement would be interpreted by those to whom the maker communicates the statement as a serious expression of an intention to inflict bodily harm or take the life of the [object].” Id. at 557 (citing cases) (threatening communication mailed to President Reagan); accord United States v. Orozco-Santillan, 903 F.2d 1262, 1265 (9th Cir. In Watts, defendant was a young man who attended a protest rally in Washington. Speaking up in an open-air discussion group, he stated, “And now I have already received my draft classification as 1-A and I have got to report for my physical this Monday coming. I am not going. If they ever make me carry a rifle the first man I want in my sights is L.B.J. They are not going to make me kill my black brothers.” 394 U.S. at 706. The other participants, as well as the speaker himself, responded to this statement with laughter.” Id. at 707. In addition, the Court noted that defendant’s “threat” was conditional, and based upon an event he vowed would never occur. Id. ,