People v. Conley

Brief Fact Summary. The Defendant, William J. Conley, was convicted by jury of aggravated battery for striking the victim, Sean O’Connell, with a wine bottle. He appealed the conviction, averring that there was no proof of an intent to cause permanent disability.

Synopsis of Rule of Law. Intent can be inferred by the circumstances surrounding the crime.

Facts. The victim attended a party with friends. During the evening his group was approached by about 20 boys who thought that someone in the victim’s group had said something derogatory. The group denied saying anything and left shortly thereafter. While walking to their car, the victim and a friend, Marty Carroll, were approached by a group of people who mentioned something about them being the guys from the party. A person, later determined to be the Defendant, emerged from the group and demanded a beer from the victim’s six-pack. When the victim refused, the Defendant stuck the victim in the face with a wine bottle. The victim sustained broken upper and lower jaws and four broken bones in the area between the bridge of the nose and the lower left cheek. The Defendant challenges his conviction on the ground that the state did not prove beyond a reasonable doubt that he intended to inflict a permanent disability.

Issue. Was the evidence sufficient to support a finding of intent to cause permanent disability beyond a reasonable doubt?

Held. Yes.
Aggravated battery requires the commission of a battery where the offender intentionally or knowingly causes great bodily harm or permanent disability or disfigurement.

The intent to cause great bodily harm may be inferred by the circumstances surrounding the offense, such as the offender’s words, the weapon used, and the force of the blow. Here, the Defendant struck the victim in the face with a bottle without warning. Hence, the jury could reasonably infer that the Defendant intended to cause permanent disability.

Discussion. Intent may be inferred from the surrounding circumstances of the crime.