Yates v. Memphis Bakery Employers Ass'n

How later courts describe this case

• equating a "true threat" with a situation "where a reasonable person would foresee that the listener will believe he will be subjected to physical violence upon his person...."
• evidence of drug transactions occurring within one hour of each other held admissible to explain entire plan or conspiracy to distribute cocaine
• no interplay between Bounds and Faretta that would require a trial court to permit a pro se defendant to have access to a law library
• upholding conviction under 18 U.S.C. § 876, mailing threatening communications
• traveling with companion is characteristic