The governing standard for incitement comes from Brandenburg v. Ohio, a Supreme Court decision arising from a Ku Klux Klan rally. The ruling permitted the government to punish incitement only when it proves that the speech was "directed to the incitement of imminent lawless action and likely to produce such action." Similarly, in the cross-burning case Virginia v. Black, the court defined "true threats" as statements meant "to communicate a serious expression of an intent to commit an act of unlawful violence to a particular individual or group of individuals."