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Keywords

defendantappealverdicttestimonydomestic violencecircumstantial evidencebeyond a reasonable doubtadmissibilitycredibility

defendanttrialtestimonymotiondomestic violence

Related Cases

Culp v. State, 178 So.3d 378

Facts

On April 8, 2008, Brandis Hand, living with her boyfriend Culp, attempted to leave their home. Culp prevented her from leaving by pushing the door closed and struck her on the jaw, causing serious injuries that required surgery. Hand's testimony, along with medical evidence, established that Culp inflicted serious physical injury on her. Culp's defense included questioning Hand's credibility and the admissibility of e-mails exchanged between them.

The evidence admitted during Culp's trial tended to establish that on April 8, 2008, Brandis Hand was living with Culp, her boyfriend, in Henry County.

Issue

Did the State establish a prima facie case of second-degree domestic violence, and were the e-mails from the defendant properly authenticated?

Culp first argues that the circuit court erred when it denied his motion for judgment of acquittal.

Rule

A person commits the crime of domestic violence in the second degree if they intentionally cause serious physical injury to a current or former household member. The evidence must demonstrate the relationship and the intent to cause injury.

Section 13A–6–131(a), Ala.Code 1975, provides: 'A person commits the crime of domestic violence in the second degree if the person commits the crime of assault in the second degree pursuant to Section 13A–6–21[, Ala.Code 1975], … and the victim is a current or former spouse, parent, child, any person with whom the defendant has a child in common, a present or former household member, or a person who has or had a dating or engagement relationship with the defendant.'

Analysis

The court found that the evidence presented, including Hand's testimony and medical records, was sufficient for the jury to conclude that Culp intentionally caused serious physical injury. The relationship between Culp and Hand met the statutory requirements for domestic violence, and the e-mails were authenticated through circumstantial evidence and testimony.

The evidence was also sufficient to allow the jury to determine that Hand suffered 'serious physical injuries.' In Anderson v. State, 686 So.2d 381 (Ala.1996), the Alabama Supreme Court held that 'testimony indicat[ing] that the victim had a deep puncture wound from a knife; trauma to the head, along with various bruises and scrapes; a fractured rib; and a burst eardrum' was sufficient to establish that the victim had suffered 'serious physical injuries.'

Conclusion

The Court of Criminal Appeals affirmed the conviction, concluding that the evidence was legally sufficient to support the jury's verdict.

Based on the foregoing, the judgment of the circuit court is affirmed.

Who won?

The State prevailed in the case because the evidence presented was sufficient to establish Culp's guilt beyond a reasonable doubt.

The State established prima facie case of second-degree domestic violence so as to allow submission of case to jury.

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Keywords

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State v. Doris, 51 Or. 136, 94 P. 44, 16 L.R.A.N.S. 660

Akin v. State, 698 So.2d 228, 78 A.L.R.5th 607

Henderson v. United States, 303 A.3d 375

Com. v. Bois, 476 Mass. 15, 62 N.E.3d 513

People v. Conley, 63 Cal.4th 646, 373 P.3d 435, 203 Cal.Rptr.3d 622, 16 Cal. Daily Op. Serv. 7001, 2016 Daily Journal D.A.R. 6585