standard,” and that it “lacks the sufficient criminal intent element that may have narrowed the law to avoid constitutional infirmity.” Caselaw supports Casillas’s argument that Minn. Stat. § 617.261’s lack of an intentto-harm element, coupled with a negligence mens rea, runs afoul of the First Amendment. For example, in A.J.B., the Minnesota Supreme Court held that Minn. Stat. § 609.749, subd. 2(6) (2018), violated the First Amendment because it was facially overbroad. 929 N.W.2d at 844. That statute provided that a person who harassed another by committing the following act was guilty of a gross misdemeanor: “repeatedly mails or delivers or causes the delivery by any means, including electronically, of letters, telegrams, messages, packages, through assistive devices for people with vision impairments or hearing loss, or any communication made through any available technologies or other objects.” Minn. Stat. § 609.749, subd. 2(6). In invalidating the statute, the Minnesota Supreme Court noted that it “subject[ed] even negligent conduct to criminal sanction” and that it “criminalize[d] communications even when the person [did] not know—much less intend—that the communication [would] frighten, threaten, oppress, persecute, or intimidate the victim.” A.J.B., 929 N.W.2d at 854-55. The supreme court concluded that “[t]he statute’s inclusion of a negligence standard [made] it more likely that the statute [would] have a chilling effect on expression protected by the First Amendment.” Id. at 855 (quotation omitted). The Minnesota Supreme Court also held that Minn. Stat. § 609.795, subd. 1(3) (2018), violated the First Amendment because it was facially overbroad. Id. at 844. That statute provided that whoever “with the intent to abuse, disturb, or cause distress, repeatedly mails or delivers or causes the delivery by any means, including electronically, 17