People v. Young

Brief Fact Summary.

Defendant Young was charged with assault, but the appellate division ruled that the assault was justified because there was a mistake of fact.

Synopsis of Rule of Law.

A criminal defendant can be convicted of assault when they  intend to cause bodily harm or immediate apprehension of bodily harm to another person.

Facts.

Young witnessed two older man beating a young boy and he proceeded to intervene, believing the boy was being assaulted, and attacked the two men. As it turns out, the two men were undercover detectives who were attempting to arrest the boy for disorderly conduct and the boy happened to be resisting arrest. When Young decided to attack the two men he had no knowledge they were undercover officers. Young was charged with assault.

Issue.

Whether a criminal defendant can be convicted of assault when they intend to cause bodily harm or immediate apprehension of bodily harm to another person, even if the assault is justified based on mistake of fact?

Held.

Yes. A criminal defendant can be convicted of assault when they intend to cause bodily harm or immediate apprehension of bodily harm to another person, even if the assault is justified based on mistake of fact.

Concurrence.

None

Discussion.

A defendant can be criminally liable when they intend to cause bodily harm or immediate apprehension of harm to another person regardless if there is a mistake of fact present. Because the motive behind the intent makes no difference, Young can be convicted of assault of the officers because he intended to cause them bodily harm. The jury can find Young not guilty of assault, but that doesn't change the fact he should still be charged and tried for it.