16 ELONIS v. UNITED STATES THOMAS, J., dissenting between the offense of making threats with the intent to extort and the offense of sending threatening letters with­ out such a requirement in their discussions of threat statutes, making it difficult to draw strong inferences about the latter category. See 2 J. Bishop, Commentaries on the Criminal Law §1201, p. 664, and nn. 5–6 (1877); 2 J. Bishop, Commentaries on the Law of Criminal Proce­ dure §975, p. 546 (1866); 25 The American and English Encyclopædia of Law 1073 (C. Williams ed. 1894). Two of Elonis’ cases appear to discuss an offense of sending a threatening letter without an intent to extort, but even these fail to make his point. One notes in pass­ ing that character evidence is admissible “to prove guilty knowledge of the defendant, when that is an essential element of the crime; that is, the quo animo, the intent or design,” and offers as an example that in the context of “sending a threatening letter, . . . prior and subsequent letters to the same person are competent in order to show the intent and meaning of the particular letter in ques­ tion.” State v. Graham, 121 N. C. 623, 627, 28 S. E. 409, 409 (1897). But it is unclear from that statement whether that court thought an intent to threaten was required, especially as the case it cited for this proposition—Rex v. Boucher, 4 Car. & P. 562, 563, 172 Eng. Rep. 826, 827 (K. B. 1831)—supports a general-intent approach. The other case Elonis cites involves a statutory provision that had been judicially limited to “ ‘pertain to one or the other acts which are denounced by the statute,’ ” namely, terror­ istic activities carried out by the Ku Klux Klan. Commonwealth v. Morton, 140 Ky. 628, 630, 131 S. W. 506, 507 (1910) (quoting Commonwealth v. Patrick, 127 Ky. 473, 478, 105 S. W. 981, 982 (1907)). That case thus provides scant historical support for Elonis’ position. B Elonis also insists that our precedents require a mental