California Supreme Court
The People, Plaintiff and Respondent v. Reginald Wyatt, Defendant and Appellant
May 10, 201048 Cal. 4th 776
Summary
The court held that substantial evidence supported Reginald Wyatt's conviction for child abuse homicide because the assault element required proof that he intentionally acted while aware of facts that would lead a reasonable person to realize great bodily injury would probably result, not proof that he subjectively recognized the risk of injury. Wyatt knew he was repeatedly striking his 14-month-old son with substantial force, and the child's extensive internal injuries supported the jury's finding. The court reversed the Court of Appeal's judgment and remanded for further proceedings. Kennard, J., concurring, agreed under controlling precedent but stated that assault should require an intent to injure.