Totality of the Circumstances. See Woollard.
No documented threat actually required. Read the statute.
Does any objective individual think the wheel chair bound applicant didn't articulate a reasonable fear of apprehended danger? Maybe those that wanted to play God and decide she couldn't exercise a fundamental right?
Improvement? Yes. Inconsistency? Yes. Inconsistency breeds contempt for the process.
Forget the rest of the MSP wannabe lawyer BS.
DAMN right!