George sent an email to Jim, a councilman for the city of San Diego. In the email, George states that Jim is a “no good pimp that spends too much time with the rich and not enough time with the poor.” Jim’s email goes on as follows: “I’m dusting off my shotgun and putting it to good use. I’ve got plenty of ammunition. I’m gonna shoot you and all those other worthless do-nothing politicians! Now is the start of a new world order!” Frightened, Jim calls the police and George was arrested and subsequently convicted of making criminal threats under California Penal Code Section 422 PC, which provides, in pertinent part: “The defendant is guilty of making criminal threats if the defendant willfully threatened to unlawfully kill or unlawfully cause great bodily injury to another person, and made the threat orally, in writing or via electronic communication.” Was George’s conviction unconstitutional under the First Amendment? Why or why not?