State v. Fuller
414 So. 2d 306 (1982)
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Rule of Law:
The crime of second-degree battery, under La.R.S. 14:34.1, is a specific intent crime, requiring the state to prove that the offender actively desired to inflict serious bodily harm.
Facts:
- Brent Brown and James Fuller were at Secret's Lounge, where they played a game of pool for a ten-dollar bet, which Brown lost and paid.
- Fuller then proposed a doubles game; Brown and his partner lost to Fuller and his partner, Mr. Brannon.
- Fuller informed Brown and his partner they owed twenty dollars, which Brown paid.
- A few minutes later, Brown approached Fuller, stating he believed the bet was for ten dollars total, not twenty, leading to an argument.
- Brannon stated there should be no fighting, and Brown, agreeing he did not want to fight, handed his pool cue to his partner.
- As Brown turned back toward Fuller, Fuller struck him in the face with his fist.
- The blow knocked Brown backwards across a pool table, causing a cut lip, a bloody nose, and vision impairment that became permanent.
Procedural Posture:
- The State of Louisiana charged James Fuller with second-degree battery by bill of information in the trial court.
- Following a bench trial, the judge found Fuller guilty as charged.
- Fuller filed a motion for a new trial, arguing the prosecution withheld exculpatory evidence; the trial court denied the motion.
- The trial court sentenced Fuller to one year in prison, suspended, with two years of supervised probation.
- Fuller appealed his conviction directly to the Supreme Court of Louisiana.
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Issue:
Does the crime of second-degree battery, as defined by La.R.S. 14:34.1, require the state to prove the defendant had the specific intent to inflict serious bodily harm?
Opinions:
Majority - Calogero, J.
Yes, the crime of second-degree battery requires specific intent. The court analyzed the statutory language, which defines the offense as a battery where 'the offender intentionally inflicts serious bodily injury.' The court reasoned that since the definition of battery itself already requires an 'intentional use of force,' the legislature's inclusion of a second, distinct intent requirement ('intentionally inflicts') signifies that the offender must have had the specific intent, or active desire, to cause the prescribed consequence of serious bodily harm. This distinguishes it from general intent crimes like aggravated battery. The court also held that specific intent can be inferred from the circumstances. In this case, the fact that a larger, older man (a bouncer) struck a smaller, younger man with a single blow of sufficient force to knock him over a pool table and cause permanent injury was sufficient for a rational trier of fact to find that the defendant possessed the requisite specific intent to inflict serious bodily harm.
Analysis:
This case establishes a significant precedent by being the first from the Louisiana Supreme Court to interpret the mens rea for the then-recently enacted crime of second-degree battery. By classifying it as a specific intent crime, the court raised the prosecution's burden of proof, requiring evidence not just of an intentional act but of the defendant's subjective desire to cause a specific, severe result. The decision provides crucial guidance for lower courts on how to distinguish second-degree battery from general intent offenses like aggravated battery. Furthermore, its analysis on inferring intent from circumstantial evidence, such as the disparity in size between the parties and the force of the blow, created a durable framework for prosecuting such cases in the future.
