United States v. Hathaway, 318 F.3d 1001, 1007 (10th Cir. 2003) (at common law simple assault was defined as "either a willful attempt to inflict injury upon the person of another, or by a threat to inflict injury upon the person of another which, when coupled with an apparent present ability, causes a reasonable apprehension of immediate bodily harm.").
jurisdiction:
Tenth Circuit