At a local NRA meeting, the chapter president was giving a speech to members when someone asked about Beto O'Rourke's recent statement needing to take action on gun control. In an offhand remark, the local NRA chapter president said that he'd like to have O'Rourke in his crosshairs (meaning to aim his gun at O'Rourke). National news outlets picked the story up, and federal prosecutors decided to press charges. By the way, O'Rourke said he wasn't afraid.

Which case that we have covered would be most useful in analyzing this hypothetical? Please give only the last name of the appellant.

Which of the following is the most appropriate legal claim/charge for the above scenario?

True Threats

Intentional Infliction of Emotional Distress

Incitement to Violence

Fighting Words