Stevens dissented on the ground that subjective intent is not a valid criterion for constitutional adjudication.

The defendant must have had a subjective intent to lie.

The standard definition of a true threat does not require actual subjective intent to carry out the threat.

Justice O'Connor said the subjective intent of the officers should make no difference, because a suspect could not know what was in an officer's mind.

So declarations of subjective intent, prior negotiations and subsequent conduct should not be ruled out as irrelevant.

Furthermore, he claimed that becoming a citizen of another state required both physical presence within the state and a subjective intent to remain there.

Obviously, this judicial acceptance of subjective intent excludes the traditional reliance on objective connecting factors, but it does work well in practice.

In doing so, we simply noted that the principle of Whren rendered the subjective intent of an officer irrelevant to this analysis.

This test is more concerned with subjective intent of each step than the "mutual interdependence" test.

This was in contrast to the other murder provisions in the Code that require a subjective intent and foresight for a conviction.