of letters, telegrams, or packages” is guilty of a misdemeanor. Minn. Stat. § 609.795, subd. 1(3). In holding that the statute was unconstitutionally overbroad, the supreme court noted that Minn. Stat. § 609.795 included a specific-intent element that limited the sweep of the statute by excluding negligent acts from the statute’s reach. A.J.B., 929 N.W.2d at 858. The supreme court said that “[u]nder certain circumstances, a specific-intent requirement may sufficiently limit the reach of a statute into protected speech and expressive conduct to avoid overbreadth.” Id. at 860. But the supreme court concluded that the “intentional conduct” element was not a sufficient limitation to save the statute, reasoning in part that “the limiting effect of the specific-intent requirement is counterbalanced by the absence . . . of any requirement that the victim actually suffer any harm.” Id. at 861. In sum, “[b]y foregoing any requirement that the harm actually occur, the Legislature criminalized behavior, including substantial speech and expressive conduct, that will have no impact on the legitimate purpose of the statute: to prevent the harm.” Id. Similarly, in Hensel, the Minnesota Supreme Court held that Minn. Stat. § 609.72, subd. 1(2) (2016), which prohibited disturbing assemblies or meetings, was facially unconstitutional under the First Amendment because it was substantially overbroad. 901 N.W.2d at 168. The supreme court reasoned in part that [r]ather than prohibiting only intentional conduct, . . . the statute’s mens-rea element prohibits actions done with knowledge or reasonable grounds to know that the act will tend to disturb others. This means that an individual need only perform an act that is negligent, which allows the statute to reach all types of acts, intentional or not, that have a tendency to disturb others. The statute’s inclusion of a negligence standard makes it more likely that the statute will have a 18