2nd DCA Upholds Injured Worker's Conviction for Making Criminal Threats

California's 2nd District Court of Appeal on Thursday upheld an injured worker's conviction for making criminal threats to a peace officer and pharmacy manager. Although Sergius Apostolos Orloff is reliant upon a wheelchair, the court said his angry utterances could still convey the requisite gravity of purpose and immediate prospect of harm to constitute a violation of Penal Code Section 422. While the court said it had "compassion for a person confined to a wheelchair," it said "pain and suffering does not give license to threaten people." A jury found Orl...