People v. Lowery, 52 Cal.4th 419 (Aug. 11, 2011) (statute prohibiting willfully threatening violence against a crime witness or victim, Pen al Code 140(a), applies only to those threatening statements that a reasonable listener would understand to constitute a true threat, and statute does not violate the First Amendment through lack of any requirement that the threat be carried out immediately or that the defendant have the apparent ability to carry it out); see Annot., Validity, construction, and application of state statutes imposing criminal penalties for influencing, intimidating, or tampering with witness (1981) 8 A.L.R.4th 769.