State v. Alvarez

May a defendant be convicted under the criminal antiharassment act of 1985 for a single threat? That question is raised by David A. Alvarez, a juvenile at the time of his two separate convictions under the act.

Alvarez contends that the act requires proof of repeated threats demonstrating a pattern of harassment and that the trial court erred in each case by finding him guilty of harassment based on a single, isolated act. He also challenges the sufficiency of the evidence establishing in each case that his conduct placed the person threatened in "reasonable fear” that the threat would be…