The People, Plaintiff and Respondent v. Reginald Wyatt, Defendant and Appellant

Summary

The court held that the assault element of child abuse homicide requires an intentional act and actual knowledge of facts that would lead a reasonable person to realize that great bodily injury would directly, naturally, and probably result, but does not require subjective awareness of the risk of injury. Applying that standard, the court found substantial evidence that defendant repeatedly struck his 14-month-old son with substantial force and caused fatal internal injuries, so it reversed the Court of Appeal and remanded. Justice Kennard, concurring, agreed that the conviction was supported under the controlling assault-mens-rea rule but stated that she had previously disagreed with that rule.